Antonio de Sousa Maia, Legal Officer, European Commission;
Cecilia Nilsson-Bottka, Policy Officer, European Commission;
Enrico Venturini, Senior Researcher, NEXT TECHNOLOGY TECNOTESSILE;
Dirk Vantyghem, Director General, EURATEX;
Clara Mallart, Senior Specialist for Sustainability, MODACC.
Summary of remarks by Dirk Vantyghem (Director General of the European Apparel and Textile Confederation, EURATEX)
EU textile and apparel companies are still struggling with an adverse business environment, from high energy bills and hiking inflation to an economic slowdown. Many companies are in trouble. New “green measures” must be careful about their impacts on companies’ business operations.
Textile and apparel is one of the most globalized sectors in the EU. Government sustainability policy must consider the global dimension of their implications on EU companies, such as the impact on fair competition and investments across borders.
Consumers’ demand for sustainable textile and apparel products, especially their willingness to pay a premium, remains a question mark.
If new sustainability regulations are implemented, it is imperative for the government to assist companies going through the transition. Small and medium-sized enterprises (SMEs) form the backbones of the textile and apparel industry. These SMEs must survive as they provide critical products and services to large-scale fashion brands.
Many green legislations impacting the EU textile and apparel industry are coming (e.g., new labeling requirements on sustainable materials). Close collaboration and dialogue between the industry and legislators are essential.
Mango is a fashion company based in Barcelona, Spain that was founded in 1984 by brothers Isak Andic and Nahman Andic. The company has grown significantly since its inception and now has over 2,700 stores in 109 countries worldwide. Mango is known for its trendy and high-quality clothing, which is targeted toward young women.
One of the critical factors in Mango’s success has been its ability to stay current and relevant in the fast-paced fashion world. The company regularly collaborates with top designers and influencers to create unique and fashionable collections that appeal to its target audience. Mango also closely monitors emerging trends and adapts its collections accordingly.
Besides clothing, Mango also offers accessories, such as bags, shoes, jewelry, and a home collection. The company has a solid online presence, with an e-commerce website that allows customers to shop from anywhere in the world.
In December 2022, Mango announced the Sustainable 2030 strategy, which “aims to move towards the full traceability and transparency of its value chain, in order to continue with the process of auditing its suppliers and ensuring that appropriate working conditions are being fulfilled for the workers in the factories the company works with around the world.” As part of the strategy, Mango will “focus its efforts on moving towards a more sustainable collection, prioritizing materials with a lower environmental impact and incorporating circular design criteria, so that by 2030 these will predominate in the design of its products and all its fibers will be of sustainable origin or recycled.”
Mango’s Apparel Sourcing Strategies (as of December 2022)
First, Mango adopted a sophisticated global sourcing network for its apparel products. Specifically, Mango’s apparel supply chain involves 1,878 Tier 1, Tier 2, and Tier 3 factories in 29 countries worldwide. About 31% of these factories produce garments (Tier 1), 19% supply fabrics (Tier 2), and 49% provide textile raw materials like yarns and accessories (Tier 3). Further, about 407 factories (or 21%) have vertical production capability (e.g., making both finished garments and textile inputs).
Second, like many EU fashion companies, near-shoring from the EU and Turkey is a critical feature of Mango’s apparel sourcing strategy. For example, about 44.8% of Mango’s Tier 1 garment suppliers were EU based (including Turkey), whereas Asia suppliers only accounted for 54%. Likewise, about 34% of Mango’s Tier 2 fabric suppliers and nearly half of its Tier 3 yarn and accessories suppliers were also EU based. The result reflects the EU’s intra-region textile and apparel trade patterns, supported by the region’s relatively complete textile and apparel supply chain. In comparison, US fashion companies typically source more than 80% of finished garments from Asia, and most of these garments also use Asia-based textile raw materials.
Third, measured by the number of suppliers, Mango’s top Tier 1 apparel production bases include Turkey (187 factories), China (176 factories), India (135 factories), and Italy (107 factories). Industry sources further indicated that between 2021 and 2022, Mango primarily sourced from Turkey and India for Tops (69% and 78%, respectively). Mango’s imports from China and Italy were more diverse in product categories (e.g., dresses, outwear, bottoms, and swimwear). On the other hand, Mango’s apparel imports from Italy were much higher priced ($107 retail price on average) than those from the other three countries ($38-41 retail price on average).
Fourth, the factory size and vertical production capabilities of Mango’s suppliers seem to vary by region. Notably, Mango’s Asia-based suppliers are more likely to be large-sized (with 1,000+ employees) and offer vertical production (e.g., making both finished garments and textile input). Mango’s Africa and America-based suppliers were relatively small-sized or lacked vertical integration.
Primarkis one of the largest fashion retailers in Europe, offering something for everyone with a wide selection of products available across womenswear, menswear, kidswear, home, health & beauty, and gifting. It has 384 stores and employs over 70,000 people in the Republic of Ireland, the UK, Spain, Portugal, Germany, the Netherlands, Belgium, Austria, France, Italy, Slovenia, Poland, and the US.
As of May 2021, Primark sources from 28 countries working with around 928 contracted factories. Of these factories, 86 percent are Asia-based. Another 10 percent and 4 percent are located in Eastern EU and Western EU countries, respectively. Primark does not own any of these factories, however.
Measured by the number of workers, Primark’s Asian factories are larger than their counterparts in other parts of the world. For example, while Primark’s factories in Pakistan and Bangladesh typically have more than 2,500+ workers, its factories in Western EU countries like the UK, Germany, Italy, and France, on average, only have 64-200 workers. This pattern suggests that Primark mainly uses Asian factories to fulfill volume sourcing orders and its EU factories mostly produce replenishment or more time-sensitive fashionable items.
Further, reflecting the unique role of the garment industry in creating economic opportunities for women,females account for more than half of the workforce in most garment factories that make products for Primark. The percentage is exceptionally high in developing countries like Myanmar (89%), Sri Lanka (78%), Vietnam (77%), and Cambodia (75%).
Regarding Primark’s China sourcing strategy, on the one hand, Primark sources from as many as 475 suppliers located in China, far more than any other Asian country. However, most of Primark’s China factories are small and medium-sized, and fewer than 1% report having 1,000+ workers. In comparison, more than 75% of Primark’s factories in Bangladesh, Pakistan, and Myanmar have 1,000+ workers. This pattern suggests that China plays a more sophisticated role in Primark’s textile and apparel supply chain and is often used to balancing flexibility and agility.
Primark’s Ethical Trade and Environmental Sustainability team comprises over 120 specialists based in key sourcing countries. The team visits and reviews every supplier factory at least once a year to ensure the factories’ standards align with Primark’s products Code of Conduct.
Every factory that manufactures products for Primark has to meet internationally recognized standards before the first order is placed and throughout the time they work with Primark.
The EU region as a whole remains one of the world’s leading producers of textile and apparel (T&A). The value of EU’s T&A production totaled EUR137.3 bn in 2019, down around 2% from a year ago (Note: Statistical Classification of Economic Activities or NACE, sectors C13, and C14). The value of EU’s T&A output was divided almost equally between textile manufacturing (EUR68.7bn) and apparel manufacturing (EUR68.6bn).
Regarding textile production, Southern and Western EU, where most developed EU members are located such as Germany, France, and Italy, accounted for nearly 75% of EU’s textile manufacturing in 2019. Further, of EU countries’ total textile output, the share of non-woven and other technical textile products (NACE sectors C1395 and C1396) has increased from 19.2% in 2011 to 23.0% in 2017, which reflects the on-going structural change of the sector.
Apparel manufacturing in the EU includes two primary categories: one is the medium-priced products for consumption in the mass market, which are produced primarily by developing countries in Eastern and Southern Europe, such as Poland, Hungary, and Romania, where cheap labor is relatively abundant. The other category is the high-end luxury apparel produced by developed Western EU countries, such as Italy, UK, France, and Germany.
It is also interesting to note that in Western EU countries, labor only accounted for 21.7% of the total apparel production cost in 2017, which was substantially lower than 30.1% back in 2006. This change suggests that apparel manufacturing is becoming capital and technology-intensive in some developed Western EU countries—as companies are actively adopting automation technology in garment production.
Because of their relatively high GDP per capita and size of the population, Germany, Italy, UK, France, and Spain accounted for nearly 60% of total apparel retail sales in the EU in 2020. Such a market structure has stayed stable over the past decade.
Data source: UNcomtrade (2021)
Intra-region trade is an important feature of the EU’s textile and apparel industry. Despite the increasing pressure from cost-competitive Asian suppliers, statistics from UNComtrade show that of the EU region’s total US$73.8bn textile imports in 2019, as much as 54.6% were in the category of intra-region trade. Similarly, of EU countries’ total US$204.0bn apparel imports in 2019, as much as 37.4% also came from other EU members. In comparison, close to 98% of apparel consumed in the United States are imported in 2019, of which more than 75% came from Asia (Eurostat, 2021; UNComtrade, 2021).
Regarding EU countries’ textile and apparel trade with non-EU members (i.e., extra-region trade), the United States remained one of the EU’s top export markets and a vital textile supplier (mainly for technical and industrial textiles). Meanwhile, Asian countries served as the dominant apparel sourcing base outside the EU region for EU fashion brands and retailers.
2021 hopefully will be a year of recovery and growthfor the EU textile and apparel industry. According to Euratex, the EU Business Confidence indicator of March 2021 gained momentum, with a confirmed upward trend in the textile industry (+3.8 points), and a modest recovery in the clothing industry (+1.6 points). However, Euratex also noted that EU textile and apparel companies still face daunting challenges and uncertainties in 2021, ranging from the rising raw material price, increasing transportation cost, to political instability in some key sourcing destinations (such as China and Myanmar).
“Hugo Boss’s sourcing strategies are relatively different from fashion brands and retailers in the US. Hugo Boss’s self-owned production facilities are all located in Europe, and they follow the general trend of Eastern Europe being responsible for mass production items and Western Europe being responsible for more of the fine craftsmanship/made-to-measure items. Hugo Boss’s production distribution, which is 53% in Europe, 40% occurs in Asia, 6% in Africa, and 1% in the Americas, is much more diverse than the production distribution of the United States’ T&A industry, which heavily relies on Asian suppliers. It is indicative of a strong regional supply chain in Europe, and because the regional supply chain in the Americas is not as strong due to complicated trade agreements and lack of production capacity, many fashion brands and retailers heavily depend on overseas production from Asian countries. “
“I think that EU’s sourcing strategies are different from the U.S.’s sourcing strategy in the sense that it is kept within Europe. In the U.S., they are currently trying to bring the sourcing supply chain back to the Western Hemisphere, but it is very difficult for fashion brands to concede when sourcing is cheaper in Asia, and there is not enough labor who are trained for the work that they need. Over at the EU, with everything kept within the organization, it is a lot easier to find factories within different countries without reducing GDP since it is kept within the organization.”
“I think that one of the biggest differences between EU and US fashion brand’s sourcing strategies is the fact that there is a much higher luxury or high-end apparel market in the EU. Since they produce mostly luxury apparel products, they naturally place a lot more emphasis on the quality of their products being made rather than the quantity and speed of production. Since the US is more fast-fashion heavy, we do a lot more outsourcing of production so retailer’s are able to produce as many clothes as possible within a short period of time at a very low cost which is simply not achievable in many US clothing factories.”
“Hugo Boss pays close attention to where they are sourcing from and where each of their products should be made within their 4 production facilities. This stuck out to me because I don’t know how many US fashion brands have their own production facilities. I know a lot of brands outsource to countries like China and Bangladesh to factories who are also making clothing for many different brands.”
“EU has developed countries as well as developing countries, unlike the US. Western EU countries like Italy, France, UK and Germany are developed and focus more so on textile production. Whereas developing countries in the EU like Poland and Hungary focus more heavily on apparel manufacturing. In addition, unlike the US, the developed countries in EU also produce apparel exports, of high level, luxury goods.”
“It seems that in the EU the main focus is quality and social standards for these fashion brands and production. In the US, promoting local economic growth seems to be more of the focus of the free trade agreements. Sourcing for HUGO BOSS at least has strategically chosen factories where they can ensure quality checks and know how to conditions are. In the US, outside of the region, it seems that there are a lot of brands who do not know their secondary producers…”
“As the EU is more focused on production in high end markets than is the US, they (EU fashion companies) source more high-end quality fabrics. Progress has been made through technological advances, as the HUGO BOSS group developed the “smart factory” to further improve the quality of their fabrics and recognize any potential flaws before production. This stood out to me as a major difference, considering the US focuses on producing more fast-fashion goods and prioritizes high productivity overall quality garments. Also, they are more careful in their selection of suppliers and strive to build more long-term relationships with their suppliers. In comparision, most US fashion companies just try to produce as cheap and fast as possible through a short-term transctional-based importer-vendor relationship.”
“I think the sourcing strategies are similar to the U.S. in the fact that they source from various countries, creating this sense of “Made in the World.” However, there are differences as well. HUGO BOSS uses their own production facilities in addition to sourcing from other countries which is something we do not see often in the US. In fact, most brands and retailers in the US do not have their own production facilities or vertical supply chain, but instead source from overseas. Additionally, HUGO BOSS carefully selects their suppliers and immediately focus on social responsibility. US sourcing strategies seem to emphsis more on finding a factory with the lowest labor costs. EU brands and retailers, on the other hand, test their suppliers with test orders before selecting them as a supplier for the brand, and immediately develop social responsibility practices, such as trainings and building relationships. In the US, brands and retailers tend to focus on social responsibility in response to bad press and typically do so by a top-down approach.”
“The sourcing strategy in the Europe cares more about social impact. Retailers and brands there promote and educate their suppliers to be sustainable and take over their social responsibility. Another one is the European fashion retailers and brands are more likely to locate their product facilities within the Europe. Since the Europe does have a relatively stable and complete supply chain, the retailers and brands are able to saving transportation cost and expand the lead time. Third, the technology becomes an important factors for retailers and brands to consider. They are attempting to utilize technology to enhance the performance and their production process. “
“Hugo Boss strives to be the most desirable fashion and lifestyle brand in the premium sector. This shows in their emphasis on design, comfort, fit, and durability, as well as being mindful of their social and environmental impacts. They maintain long term relationships with a careful selection of suppliers, demand social compliance, and stay up to date with their “smart factory” aka AIs to speed up production and quality. They also source heavily from Asia, but also developed countries such as Italy and Germany. These values and practices are manifested in American brands, however, I believe we aren’t as extensive with sourcing from developed countries (such as Italy). From what I have learned thus far, it seems we source from countries close by and/or developing, but not so much mingling with luxury known countries, such as France or Italy (and if we do, the prices are expensive, and American customers don’t want to pay higher prices). We (US), too, source heavily from Asia, because it is cheap, and still focus internally on our own country when it comes to being more competitive in technological advancements. American and EU consumers alike value transparency in the clothing brands they buy from, and American brands are mindful of this, too. I would say we are more alike than different.”
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1. The garment industry matters significantly to Cambodia, both economically, and socially. As of 2019, as much as 70% of Cambodia’s merchandise exports were apparel items. Likewise, around one-third of Cambodia’s manufacturing output currently comes from the garment sector alone. Further, as of 2016, the garment industry in Cambodia employed nearly 928,600 workers (almost 79% were female), an increase of 239% from 2007.
2. Cambodia’s apparel exports have enjoyed steady growth in recent decades, reaching US$7.83 billion in 2018 – a jump of 256% from US$2.2 billion in 2005. Yet, it faces several major challenges:
Due to limited production techniques and capital availability, apparel producers in Cambodia are still mostly engaged in cut-make-trim (CMT) activities, meaning they rely heavily on imported textile raw material and are only able to make a marginal profit based on low-value-added sewing work.
Cambodia’s apparel exports are highly concentrated on the EU and the US markets, which together accounted for 73.4% of the country’s total garment exports in 2019.
Cambodia is facing intense competition in its main apparel export markets—there has been little growth in Cambodia’s share of EU and US apparel imports over the past two decades, remaining as low as 3% as of 2019.
3. Cambodia has benefited significantly from the EU Everything But Arms (EBA) program. Established in 2001, the EBA trade initiative provides least developed countries (LDCs), such as Cambodia, with duty-free and quota-free access to the vast EU market for all products except weapons and ammunition. Like other EBA beneficiary countries, the majority (around 95%) of Cambodia’s apparel exports to the EU currently claim the duty- and quota-free EBA benefits.
4. Out of concerns over Cambodia’s “serious and systematic violations of the human rights principles enshrined in the International Covenant on Civil and Political Rights,” the European Commission on 12 February 2020 formally announced the withdrawal of part of the tariff preferences granted to Cambodia under the EBA program. Starting from 12 August 2020, a select group of Cambodia’s apparel exports to the EU, together with all travel goods, sugar, and some footwear will be subject to the EU’s Most-Favored-Nation (MFN) tariff rat, which were at the rate of 11.5% on average for apparel items in 2019.
5. Even the partial suspension of Cambodia’s EBA eligibility could result in significant and lasting negative impacts on its apparel exports to the EU:
The apparel items directly affected by the EBA suspension accounted for around 15% of the value of Cambodia’s total apparel exports to the EU in 2019. For those apparel categories directly targeted by the EBA suspension, EU fashion brands and retailers may quickly shift sourcing orders from Cambodia to other supplying countries to avoid paying the additional tariffs.
Social responsibility is being given more weight in fashion companies’ sourcing decisions. This means even those apparel items not directly targeted by the EU EBA suspension could face widespread order cancellations as sourcing from Cambodia is deemed to involve higher social compliance risks. In a worse but possible scenario, Cambodia’s apparel exports to the whole world could be under threat as many EU fashion brands and retailers operate globally and adopt a unified ethical standard and code of conduct for apparel sourcing across different markets.
Additionally, the timing cannot be worse: Due to the devastating hit by Covid-19, as of April 2020, Cambodia had reported nearly 130 garment factory closures and more than 100,000 workers laid off. These numbers may increase further as the effect of the pandemic continue to unfold.
Vietnam’s National Assembly officially approved the EU-Vietnam Free Trade Agreement (EVFTA) on 8 June 2020, which is expected to take into effect as early as in August 2020.
EVFTA will eliminate nearly all tariffs (over 99%) between the EU and Vietnam. However, textile and apparel (T&A) are among a few exceptions that will not be able to enjoy duty-free treatment on day one. Specifically:
Created by Dr. Sheng Lu based on the EVFTA text
The EU will eliminate duties with more extended staging periods (up to 7 years) for some sensitive products in the textile apparel and footwear sectors (see the graphs above).
By adopting the fabric-forward rules of origin (or the so-called “double transformation”) for apparel items, EVFTA intends to prevent products from a third party (such as China) from flooding the EU market. Specifically, to benefit from preferential access, garments will need to use fabrics produced in Vietnam or the EU. However, through the EVFTA cumulation provision, fabrics originating in South Korea or other ASEAN countries with which the EU has a free trade agreement in force will be considered as originating in Vietnam. (Note: South Korea is a free trade agreement partner of the EU). While China remains the top textile supplier for Vietnam, the EVFTA apparel-specific rules of origin will provide more incentives for Vietnam to reduce its China dependence and restructure its textile and apparel supply chain. On the other hand, the totality of EU textile fabric exports to Vietnam will be liberalized immediately when the agreement enters into force.
Statistics show that Vietnam was EU’s sixth-largest extra-region apparel supplier in 2019 (after China, Bangladesh, Turkey, India, and Cambodia), accounting for 4.3% in value (or US$4.3 billion). Many of Vietnam’s primary competitors already enjoyed duty-free market access to the EU, such as Turkey (through the Customs Union), Bangladesh, and Cambodia (through the EU Everything But Arms program). EVFTA will provide a level playing field for Vietnam, which is expected to see a continuous robust growth of its apparel exports to the EU and gain additional market shares in the years to come. Meanwhile, not eligible for any EU preferential duty benefit, apparel exports from China are likely to face intensified competition in the EU market after the implementation of EVFTA.
EVFTA may further encourage investment in Vietnam’s textile industry. Notably, EVFTA and CPTPP together will make Vietnam one of the very few apparel exporters in the world that can enjoy duty free market access (though not immediately) to both the EU and Japan (or 40% of the world’s total apparel import market). That being said, restrained by the country’s relatively small population, the apparel industry is increasingly facing the challenge of competing for labor with other export-oriented sectors in Vietnam, which may also try to expand their production and export by taking advantage of the CPTPP and EVFTA.
The EU region as a whole remains one of the world’s leading producers of textile and apparel (T&A). The value of EU’s T&A production totaled EUR146.2bn in 2018, marginally up 2% from a year ago (Note: Statistical Classification of Economic Activities or NACE, sectors C13, and C14). The value of EU’s T&A output was divided almost equally between textile manufacturing (EUR77.4bn) and apparel manufacturing (EUR70.0bn).
Regarding textile production, Southern and Western EU, where most developed EU members are located such as Germany, France, and Italy, accounted for nearly 73.7% of EU’s textile manufacturing in 2018. Further, of EU countries’ total textile output, the share of non-woven and other technical textile products (NACE sectors C1395 and C1396) has increased from 19.2% in 2011 to 23.0% in 2017, which reflects the on-going structural change of the sector.
Apparel manufacturing in the EU includes two primary categories: one is the medium-priced products for consumption in the mass market, which are produced primarily by developing countries in Eastern and Southern Europe, such as Poland, Hungary, and Romania, where cheap labor is relatively abundant. The other category is the high-end luxury apparel produced by developed Western EU countries, such as Italy, UK, France, and Germany.
It is also interesting to note that in Western EU countries, labor only accounted for 21.7% of the total apparel production cost in 2017, which was substantially lower than 30.1% back in 2006. This change suggests that apparel manufacturing is becoming capital and technology-intensive in some developed Western EU countries—as companies are actively adopting automation technology in garment production.
Because of their relatively high GDP per capita and size of the population, Germany, Italy, UK, France, and Spain accounted for 61.1% of total apparel retail sales in the EU in 2018. Such a market structure has stayed stable over the past decade.
Data source: UNcomtrade (2020)
Intra-region trade is an important feature of the EU’s textile and apparel industry. Despite the increasing pressure from cost-competitive Asian suppliers, statistics from the World Trade Organization (WTO) show that of the EU region’s total US$73.7bn textile imports in 2018, as much as 57.1% were in the category of intra-region trade. Similarly, of EU countries’ total US$205.0bn apparel imports in 2018, as much as 48.0% also came from other EU members. In comparison, close to 97% of apparel consumed in the United States are imported in 2018, of which more than 80% came from Asia (Eurostat, 2020; WTO, 2020).
The EU textile and apparel industry is not immune to COVID-19. According to the European Apparel and Textile Federation (Euratex), the outbreak of COVID-19 may cause a 50% drop in sales and production for the EU textile and apparel sector in 2020. A recent survey of EU-based T&A companies shows that almost 9 out of 10 respondents reported facing serious constraints on their financial situation and 80% of companies had temporarily laid-off workers. Around 25% of surveyed companies were considering closing down their businesses. Further, EU T&A companies were concerned about EU’s tightened border controls, which have “increased sharply, leading to delays in supplies but also cancelling of orders, thus aggravating the economic impact.”
The UK government on March 13, 2019 released the temporary
rates of customs duty on imports if the country leaves the European Union
with no deal. In the case of no-deal Brexit, these tariff rates will take
effect on March 29, 2019 for up to 12
months.
According to the announced plan, around 87% of UK’s imports by value would be eligible for zero-tariff in the no-deal Brexit scenario.
Specifically for apparel products, 113 out of the total 148 tariff lines (8-digit HS code) in Chapter 61 (Knitted apparel) and 145 out of the total 194 tariff lines (8-digit HS code) in Chapter 62 (Woven apparel) will be duty-free. However, other apparel products will be subject to a Most-Favored-Nation (MFN) tariff rate ranging from 6.5% to 12%.
Meanwhile, the UK will offer preferential tariff duty rates for apparel exports from a few countries/programs, including Chile (zero tariff), EAS countries (zero tariff), Faroe Islands (zero tariff), GSP scheme (reduced tariff rate), Israel (zero tariff), Least Developed Countries (LDC) (zero tariff), Palestinian Authority (zero tariff), and Switzerland (zero tariff).
On the other hand, the EU Commission said it would apply the Most-Favored-Nation (MFN) tariff rates on UK’s products in the no-deal Brexit scenario rather than reciprocate.
On
October 16, 2018, the Trump
Administration notified U.S. Congress its intention to negotiate the
U.S.-EU Free Trade Agreement. Between
2013 and 2016, the United States and EU were also engaged in the negotiation of
a comprehensive free trade agreement– Trans-Atlantic Trade and Investment Partnership
(T-TIP) with the goal to unlock market access opportunities for
businesses on both sides of the Atlantic through the ambitious elimination of
trade and investment barriers as well as enhanced regulatory coherence. The T-TIP
negotiation was stalled since 2017, although
the Trump Administration has never officially announced to withdraw from the
agreement.
II. Negotiating Objectives
On
January 11, 2019, the Office of the U.S. Trade Representative (USTR) released
thenegotiating
objectives of the proposed U.S.-EU Free Trade Agreement after
seeking inputs from the public. Overall, the proposed agreement aims to address
both tariff and non-tariff barriers and to “achieve fairer, more balanced trade”
between the two sides.
Regarding textiles and apparel, USTR says it will secure duty-free access for U.S. textile and
apparel products and seek to improve competitive opportunities for exports of
U.S. textile and apparel products while taking into account U.S. import
sensitivities” during the negotiation. The proposed U.S.-EU free trade
agreement also will “establish origin procedures for the certification and
verification of rules of origin that promote strong enforcement, including with respect to textiles.” T-TIP
had adopted similar negotiating objectives for the textile and apparel sector.
III. Industry viewpoints on the agreement
As of
January 2019, leading trade associations
representing the U.S. apparel industry and the EU textile and apparel industries
have expressed support for the proposed U.S.-EU Free Trade Agreement. In general,
these industry associations recommend the agreement to achieve the following
goals:
First, eliminate import duties. For example:
American
Apparel and Footwear Association (AAFA): “We
support the immediate and reciprocal elimination of the high duties that both
countries maintain on textiles, travel goods, footwear, and apparel.”…” We also
support the immediate elimination of any retaliatory duties imposed by the
E.U., as well as any duties imposed by the U.S. (that led to that retaliation).
The duties impose costs on activities, including manufacturing activities in
the U.S., and undermine markets for U.S. exporters in Europe.”
European
Apparel and Textile Confederation (Euratex):“The
European Textile and Clothing sector faces high tariffs while exporting to the
US market from 11% to up to 32% for some products, namely sewing thread of
man-made filaments, suits, woven fabrics of cotton, trousers and t-shirts. Zero
customs duties while ensuring modern rules of origin will allow EU companies to
boost exports and offer more choice to American consumers and professional
buyers.”
Second, promote regulatory coherence (Harmonization). For example:
AAFA: “The E.U. and the
United States both maintain an extensive array of product safety, chemical management,
and labeling requirements regarding apparel (including legwear), footwear,
textiles, and travel goods.”…” Yet they often contain different requirements,
such as testing or certification, that greatly add compliance costs.”…” We
believe the U.S.‐E.U. trade agreement presents an important opportunity to achieve
harmonization or alignment for these regulations.”
Euratex: “Maintaining high
level of standards while eliminating unnecessary burdens, removing additional
requirements and facilitating customs procedures that impede business are top
priorities. Mutual recognition of the EU and US standards will preserve high
level of consumer protection on both sides of the Atlantic. Convergence on labelling (fibre
names, care symbols and wool labelling),
consumer safety on children products and flammability standards is key for the
T&C sector.” “EURATEX believes the EU and US standardization bodies should
cooperate on setting standards for Smart Textiles taking into account the
industry views for facilitating development and trade of such products of the
future.”
Third, adopt flexible/modern rules of origin. For example:
AAFA: “We should also support higher usage of the agreement by making sure the rules of origin reflect the realities of the industry today…”the yarn forward” rules, although theoretically promote usage of trade partner inputs, in practice they operate as significant barriers that restrict the ability of companies to use a trade agreement in many cases”…” We need to incorporate sufficient flexibilities into the rules of origin so that different supply chains –and the U.S. jobs they support – can take advantage of the agreement.”
Euratex: “Zero customs
duties while ensuring modern rules of
origin will allow EU companies to boost exports and offer more choice to
American consumers and professional buyers.”
The National Council of Textile Organizations (NCTO), which represents the U.S. textile industry, hasn’t publically stated its position on the proposed U.S.-EU Free Trade Agreement. However, NCTO had strongly urged U.S. trade negotiators to adopt a yarn-forward rule of origin in T-TIP. NCTO also opposed opening the U.S. government procurement market protected by the Berry Amendment to EU companies.
IV. Patterns of U.S.-EU textile and apparel trade
The
United States and the EU are mutually important textile and apparel (T&A)
trading partners. For example, the United States is EU’s largest extra-region
export market for textiles, and EU’s fifth largest extra-region supplier of
textiles in 2017 (Euratex, 2018).
Meanwhile,
the EU is one of the leading export markets for U.S.-made technical textiles as
well as an important source of high-end apparel products for U.S. consumers (OTEXA,
2018). Specifically, in 2017, U.S. T&A exports to the European Union
totaled $2,572 million, of which 73.2% were textile products, such as specialty
& industrial fabrics, felts & other non-woven fabrics and filament
yarns. In comparison, EU’s T&A exports to the United States totaled $4,163
million in 2017, among which textiles and apparel evenly accounted for 48.7%
and 51.3% respectively.
V. Potential economic impact of the agreement
By adopting the Global Trade Analysis Project (GTAP) model, Lu (2017) quantitatively evaluated the potential impact of a free trade agreement between the U.S. and EU on the textile and apparel sector. According to the study:
First,
the trade creation effect of the agreement will expand the EU-U.S.
intra-industry trade for textiles. Meanwhile, the agreement is likely to
significantly expand EU’s apparel exports to the United States.
Second,
the trade diversion effect of the U.S.-EU Free Trade Agreement will affect other
T&A exporters negatively, including Asia’s T&A exports to the U.S. market
and EU and Turkey’s T&A exports to the EU market.
Third, the U.S.-EU Textile and Apparel Trade might affect the intra-region T&A trade in the EU region negatively but in a limited way.
Overall, the study suggests that the EU T&A industry will benefit from the additional market access opportunities created by the U.S.-EU Free Trade Agreement.One important factor is that the U.S. and EU T&A industries do not constitute a major competing relationship. For example, the United States is no longer a major apparel producer, and EU’s apparel exports to the United States fulfill U.S. consumers’ demand for high-end luxury products. The U.S.-EU Free Trade Agreement is also likely to create additional export opportunities for EU textile companies in the U.S. market, especially in the technical textiles area, which accounted for approximately 40% of EU’s total textile exports to the United States in 2017 measured in value. Compared with traditional yarns and fabrics for apparel making purposes, technical textiles are with a greater variety in usage, which allows EU companies to be able to differentiate products and find their niche in the U.S. market.
Further, the study suggests that we shall pay more attention to the details of non-tariff barrier removal under the U.S.-EU Free Trade Agreement, which could result in bigger economic impacts than tariff elimination.
FASH455 Global Apparel & Textile Trade and Sourcing 