#1: How do the ‘double transformation‘ rules of origin in most EU free trade agreements benefit or hurt the EU textile and apparel industry? What are the economic, geographic and policy factors behind the growing intra-region textile and apparel trade in the EU?
#2: The EU region is a leading producer of textiles and apparel. What effect do you think the proposed EU-US trade agreement will have on big-name EU fashion brands such as Hugo Boss? What effect do you think the agreement will have on textile and apparel production in the EU as a whole?
#3: Why or why not do you think the EU textile and apparel industry is immune to the ongoing US-China tariff war?
#4: Comparing VF Corporation with Hugo Boss, what are the similarities and differences of their sourcing strategies? How might their respective sourcing strategy involve in the next 3-5 years and why?
#5: With such an emphasis on the merging of technology, data analytics, and differentiation in the textile and apparel industry worldwide, do you think it is possible for a small European apparel brand to compete with larger companies in the region? If so, how?
On 16 September 2019, the Trump administration notified U.S. Congress of its intent to enter into a trade agreement on “tariff barriers” with Japan as well as an “executive agreement” on digital trade. According to the announcement, the Trump administration plans to utilize Section 103(a) of the 2015 Trade Promotion Authority law, which allows the president to modify tariffs WITHOUT congressional approval. While details of the tariff agreement are not yet available, U.S. Trade Representative Robert Lighthizer in August said the deal with Japan would focus on beef, pork, wheat, dairy products, wine, and ethanol, as well as on industrial goods.
The 16 September notification also says the Trump administration will “further negotiations with Japan to achieve a comprehensive trade agreement that results in more fair and reciprocal trade between the United States and Japan.” Such a more comprehensive trade agreement, however, will require congressional approval.
On December 21, 2018, Office of the U.S. Trade Representative (USTR) released negotiating objectives of the proposed U.S.-Japan Free Trade Agreement (USJTA). Overall, USJTA aims to address both tariff and non-tariff barriers to achieve fairer and more balanced trade between the two countries. Regarding the textiles and apparel sector, 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. USJTA also will “establish origin procedures for the certification and verification of rules of origin that promote strong enforcement, including with respect to textiles.”
Should the newly announced U.S.-Japan trade deal remove the tariffs for textiles and apparel traded between the two countries, the overall economic impact on related trade flows could be modest. Data from the UNComtrade shows that in 2018 U.S. imported $656 million textiles (SITC 26 and 65) and $88 million apparel (SITC 84) from Japan, accounting for 2.1% and 0.1% of total U.S. textile and apparel imports respectively. Meanwhile, in 2018 Japan imported around $353 million textiles and $121 million apparel from the U.S., accounting for 3.7% and 0.4% of Japan’s total textile and apparel imports that year respectively.
In comparison, over 70% of U.S. textile and apparel exports went to the Western-Hemisphere and U.S. imported textiles and apparel mostly from NAFTA & CAFTA-DR members and other Asian countries (such as China and Vietnam). Likewise, Japan also has a much closer trade tie with other Asian countries because of the regional textile and apparel trade patterns (or commonly known as “factory Asia”).
On the other hand, the elimination of tariffs and potentially non-tariff barriers under the U.S.-Japan trade deal could expand the bilateral trade flows for technical textiles. Notably, the top categories of U.S. textile and apparel exports to Japan in 2018 were mostly technical textiles such as specialty and industrial fabrics, filament yarns, and non-woven textiles. Likewise, the top categories of Japan’s textile and apparel exports to the U.S. in 2018 also include special-purpose fabric, non-woven fabric, and synthetic filament fabrics.
Additionally, the textiles and apparel-specific rules of origin (RoO) is likely to remain a heated debate in the US-Japan trade negotiation. To protect the interests of the U.S. textile industry and the Western-Hemisphere regional textile and apparel supply chain, most free trade agreements enacted in the United States adopt the so-called “yarn-forward” RoO. Even though the U.S.-Japan trade agreement may not be a too big deal economically, the U.S. textile industry is unlikely to give up the RoO fight. However, most free trade agreements enacted in Japan adopt more liberal fabric-forward rules of origin (or commonly called “double transformation”). As textile and apparel production in Japan is increasingly integrated with other Asian countries, the strict “yarn-forward” RoO could prevent Japanese textile and apparel exporters from enjoying the preferential duty benefits under the U.S.-Japan trade agreement fully.
While U.S. textile manufacturers and the apparel and retail
industries have expressed overall support for the newly reached
US-Mexico-Canada Free Trade Agreement (USMCA or NAFTA2.0), textile producers
and the apparel sector still hold divergent views on certain provisions:
Rule of Origin
USMCA vs. NAFTA1.0: The
USMCA will continue to adopt the “yarn-forward” rules of origin. The USMCA will
also newly require sewing thread, coated fabric, narrow elastic strips, and
pocketing fabric used in apparel and other finished products to be made in a
USMCA country to qualify for duty-free access to the United States.
U.S. textile industry: U.S.
textile manufacturers almost always support a strict “yarn-forward” rules of
origin in U.S free trade agreements and
they support eliminating exceptions to the “yarn forward” rule as well. The
National Council of Textile Organization (NCTO) estimates that a yearly USMCA
market for sewing thread and pocketing fabric of more than $300 million.
U.S. apparel and retail
industries: The U.S. apparel industry opposes “yarn forward” and argues
that apparel should be considered of
North American origin under a more flexible regional “cut and sew” standard,
which would provide maximum flexibility for sourcing, including the use of
foreign-made yarns and fabrics.
Levels (TPL) for Textiles and Apparel
USMCA vs. NAFTA1.0: With some adjustments, the USMCA would continue a program that allows duty-free access for limited quantities of wool, cotton, and man-made fiber apparel made with yarn or fabric produced or obtained from outside the NAFTA region, including yarns and fabrics from China and other Asian suppliers.
U.S. textile industry: The
textile industry contends China is a major
beneficiary of the current NAFTA TPL mechanism, and it strongly pushed for its
complete elimination in the USMCA.
U.S. apparel and retail
industries: U.S. imports of textiles and apparel covered by the tariff preference level mechanism supply 13% of
total U.S. textile and apparel imports from Canada and Mexico. Apparel
producers assert that these exceptions give regional producers flexibility to
use materials not widely produced in North America.
Viewpoints on other Provisions in USMCA
U.S. textile industry: The
U.S. textile industry also opposes the USMCA newly allows visible lining fabric
for tailored clothing could be sourced
from China or other foreign suppliers, and it would permit up to 10% of a
garment’s content, by weight, to come from outside the USMCA region (up from 7%
in NAFTA1.0). The U.S. textile industry also welcomes that the USMCA would add specific textile verification and
customs procedures aimed at preventing fraud and transshipment. Additionally, the U.S. textile industry is also pleased
that the USMCA would end the Kissell
Amendment. The Kissell Amendment is an exception in NAFTA that allows
manufacturers from Canada and Mexico to qualify as “American” sources when Department
of Homeland Security (DHS) buys textiles, clothing, and footwear using
appropriated funds (about $30 million markets
for textiles, clothing, and shoes altogether).
U.S. apparel and retail
industries: Apparel importers are of
concern that the USMCA continue to incorporate the existing NAFTA short
supply procedure, which is extremely difficult to get a new item approved and
added to the list, limiting their flexibility to source apparel with inputs
from outside North America.
Finally, the report argues that “Regardless of whether the USMCA takes effect, the global competitiveness of U.S. textile producers and U.S.-headquartered apparel firms may depend more on their ability to compete against Asian producers than on the USMCA trade rules.”
First, in general, USMCA still adopts the so-called “yarn-forward” rules of origin. This means that fibers may be produced anywhere, but each component starting with the yarn used to make the garments must be formed within the free trade area – that is, by USMCA members.
Second, other than the source of yarns and fabrics, USMCA now requires that some specific parts of an apparel item (such as pocket bag fabric) need to use inputs made in the USMCA region so that the finished apparel item can qualify for the import duty-free treatment.
Third, USMCA allows a relatively more generous De minimis than NAFTA 1.0.
1) Compared with NAFTA, USMCA will cut the TPL level, but only to those product categories with a low TPL utilization rate;
2) Compared with NAFTA, USMCA will expand the TPL level for a few product categories with a high TPL utilization rate.
Fifth, USMCA will make no change to the Commercial availability/short supply list mechanism in NAFTA 1.0.
Sixth, it remains to be seen whether USMCA will boost Made-in-the-USA fibers, yarns and fabrics by limiting the use of non-USMCA textile inputs. For example, while the new agreement expands the TPL level for U.S. cotton/man-made fiber apparel exports to Canada (currently with a 100 percent utilization rate), these apparel products are NOT required to use U.S.-made yarns and fabrics. The utilization rate of USMCA will also be important to watch in the future.
Before taking into effect, USMCA still needs to be ratified by all member countries. In the United States, the earliest that President Trump can sign the agreement will be 11/29/2018 (i.e., 90 days after notifying the Congress). The U.S. International Trade Commission has until 3/14/2019 (i.e., 150 days after President signing the agreement) to release an assessment of the new trade agreement. Afterward, the Trump Administration will need to work with the Congress to develop legislation to approve and implement the agreement.
#1 How do rules of origin (RoO) and free trade agreement (FTA) regulations affect speed to market in apparel sourcing? Do countries who are part of an FTA find it to be easier to get to market in a shorter amount of time if they are working with other FTA members? Or could RoO slow down the production process because producers have to be more careful about compliance with the complicated RoO?
#2 Why or why not the “yarn forward” rules of origin remains an effective way to promote textile and apparel production in the Western-Hemisphere? What other options are available to improve the competitiveness of the Western-Hemisphere textile and apparel supply chain?
#3 What would happen to the Western-Hemisphere textile and apparel supply chain should NAFTA no longer exist?
#4 Should NAFTA be responsible for the loss of US apparel manufacturing jobs? Any hard evidence?
#5 If you were U.S. trade negotiators, what would you do with TPL in NAFTA given the competing views from the U.S. textile industry and U.S. fashion brands and retailers?
The Outlook of “Factory-Asia”
#6 From the perspective of the U.S. textile and apparel industry, is it a good idea for the United States to reach free trade agreement (FTA) with Asian countries? If so, what countries should be included in the new FTA? If not, why?
#7 How can U.S. companies get involved in the Asia-based textile and apparel supply chain?
#8 Why or why not is the “Flying geese model” unique to Asia? Can the model be replicated in America too?
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The United States maintains a bilateral trade surplus in yarns and fabrics ($4.1 billion in 2016) as well as made-up textiles ($720 million in 2016) with NAFTA members.
Regarding apparel, the United States had a trade surplus with Canada of $1.4 billion and a trade deficit with Mexico of $2.7 billion in 2016.
Impact of NAFTA on employment and production in the U.S. textile and apparel industry
The effects of NAFTA are NOT straightforward, and the drop in U.S. domestic textile and apparel production and jobs cannot be blamed solely on NAFTA.
The U.S. International Trade Commission (USITC) concluded that imports of textiles had a tiny effect on U.S. textile industry employment (a 0.4% decline) from 1998 to 2014, which covers most of the period since NAFTA’s enactment. However, the collapse of the U.S. domestic apparel industry and changing clothing tastes may have had a more significant impact on domestic textile production.
There is little evidence that NAFTA was the decisive factor for the loss of jobs in the U.S. apparel manufacturing sector, given that the major growth in apparel manufacturing for the U.S. market has occurred in Asian countries that receive no preferences under NAFTA.
Impact of the Tariff Preference Level (TPL) in NAFTA
In nearly every year since 2010, Mexico has come close to exporting the maximum allowable amount of cotton and man-made fiber apparel with duty-free foreign content. Canada’s TPL fill rates are typically highest for cotton and man-made fiber fabric and made-up products but are not usually fully filled.
It is not clear that eliminating the TPL program would result in a substantial return of textile production or jobs to the United States;if it were to raise the cost of Mexican apparel production, it could instead result in imports from other countries displacing imports from Mexico.
Other than U.S. fashion brands and retailers, Mexico and Canada reportedly oppose the elimination of the NAFTA TPL program too.
Possible Effects of Potential NAFTA Modification
Mexico’s focus on basic apparel items suggests that S. importers could quickly source from elsewhere if duty savings under NAFTA are eliminated. However, even now, some U.S. fashion companies say the duty savings are not worth the time and resources required to comply with the NAFTA rules of origin and documentation requirements. In 2016, roughly 16% of qualifying textile and apparel imports from NAFTA failed to take advantage of the duty-free benefits and instead paid applicable tariffs.
Whatever the outcome of the NAFTA renegotiation, in the medium and long run, the profitability of the North American textile and apparel industry will likely depend less on NAFTA preferences such as yarn forward and more on the capacity of producers in the region to innovate to remain globally competitive.
One change in NAFTA proposed by the United States would require motor vehicles to have 85% North American content and 50% U.S. content to qualify for tariff-free treatment. If auto manufacturers were to import more passenger cars from outside the NAFTA region and pay the 2.5% U.S. import duty rather than complying with stricter domestic content requirements, automotive demand for U.S.-made technical textiles could be adversely affected.
If the TPP-11 countries strike a trade deal, one possible effect is that Canada and Mexico may import more textile and apparel products from other TPP countries, including Vietnam. This could ultimately be a disadvantage for U.S.-based producers. How the inclusion of Canada and Mexico in a fresh TPP-11 arrangement would affect their participation in NAFTA is unknown.
#1 The US textile industry and the fashion retailers/brands/importers have very different priorities regarding modernizing and updating NAFTA. Do you believe that a compromise acceptable to both sides can be found? If so, what do you believe that compromise can be?
#2 Overall, why or why not do you think the U.S. textile and apparel industry is a beneficiary of NAFTA over the past decade? From the perspective of the U.S. textile and apparel industry, should or should not reducing the U.S. trade deficit be a prioritized objective in the NAFTA renegotiation?
#3 What will happen to the U.S. textile and apparel industry if NAFTA is gone? How should U.S.-based textile and apparel companies respond to NAFTA’s termination?
#4 In your view, why or why not the “yarn-forward” rules of origin are outdated in today’s global-based textile and apparel supply chain?
#5 Why do you think the “yarn-forward” rules of origin vary from free trade agreement (FTA) to FTA? Do you think there’s a way to make a universal “yarn-forward” rule for all U.S. FTAs?
#6 Why are the textile-specific rules of origin under free trade agreements so complex? What potential issues do you think can arise because of the complexity of these rules?
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