Tag: tariff

Apparel Sourcing and Trade Outlook for 2026

Top challenges in 2026

I believe the global fashion apparel industry will continue to face two macro-level challenges in 2026. One is the relatively weak consumer demand for clothing amid sluggish economic growth and persistent inflationary pressures. For example, according to the International Monetary Fund’s (IMF) October 2025 forecast, global GDP growth in 2026 is expected to decrease from 3.2% in 2025 to 3.1% in 2026. Specifically, U.S. GDP growth will be around 2.1% (down from 2.8% in 2024), and growth in the EU could drop to 1.1% (down from 1.2% in 2025).

Likewise, several consulting firms forecast that clothing retail sales in key apparel import markets, including the United States and Western Europe, could be stagnant or even decline in 2026. Notably, while Gen Z (i.e., those born between 1997 and 2012) has increasingly become a key customer group for many fashion brands and retailers, analysis shows that this generation has turned more cautious about shopping for clothing, especially for new items. The tariff-driven price increases could further discourage these groups from buying new clothing in the new year ahead.

Meanwhile, the trade policy environment facing the global fashion apparel industry could remain highly uncertain in 2026. Notably, in addition to tariffs, several trade agreements could create new uncertainties for fashion companies when sourcing from affected regions. Specifically:

The U.S.-Mexico-Canada (USMCA) trade agreement will begin its formal six-year review process in 2026. Despite broad industry support for upholding the existing agreement and calls to “do no harm,” we cannot rule out the possibility that the Trump administration might seek significant renegotiation or even replace the USMCA with separate bilateral trade deals.

Likewise, the outlook for the African Growth and Opportunity Act (AGOA) and the Haiti HELP/HOPE program, both of which expired in September 2025, remained highly uncertain. Because both programs play a critical role in supporting U.S. apparel sourcing from Sub-Saharan Africa and Haiti, whether and under which conditions they are renewed will directly influence fashion companies’ sourcing decisions and the long-term competitiveness and investment prospects of these regions.

Furthermore, even with several “trade deals” reached between the US and major trading partners like the EU, Vietnam, Cambodia, and potentially China and India, their implementation and enforcement will warrant close attention. In particular, the meaning and definition of critical terms like “transshipment” in these “trade deals” remain largely unclear. However, the impact could be significant for apparel sourcing if the Trump administration ultimately decides to revisit or set new rules of origin in these agreements to reduce the “China content” in products imported into the United States. Notably, according to OECD’s newly released “trade in value-added database,” apparel exports from Asian countries, including Vietnam and Cambodia, commonly contain 20-30% of value created in China.

Key apparel sourcing trends to watch in 2026

First, trade and economic impacts of tariffs could become more visible and significant in 2026. In particular, almost all U.S. apparel imports will be subject to the higher tariffs in 2026, leaving fashion companies with fewer options to use existing inventory to mitigate the effects. Consequently, fashion companies will face increased pressure to control their sourcing costs and protect their profit margins.

Second, fashion companies will continue to leverage sourcing diversification to navigate market and trade policy uncertainties. For example, according to the 2025 Fashion Industry Benchmarking Study released by the U.S. Fashion Industry Association (USFIA), a record-high percentage of surveyed U.S. fashion brands and retailers (i.e., over 80%) reported sourcing from 10 or more countries. Nearly 60% of respondents plan to source from even more countries in 2026. In a recent study I conducted, some leading U.S. and EU fashion companies mentioned in their 2025 Q2 earnings call transcripts that they intentionally seek vendors with production capacity across multiple countries to achieve sourcing diversification and mitigate risks.

Third, in addition to seeking competitive sourcing costs, fashion companies will increasingly look for vendors that can offer speed to market, flexibility, and agility. As one leading fashion company noted, “increasing the speed” does not necessarily mean “nearshoring,” but also refers to vendors that can deliver products quickly and at scale. Meanwhile, fashion companies increasingly expect suppliers to accommodate last-minute order changes, accept low minimum order quantities (MOQs), arrange raw material sourcing, and offer other value-added services. This shows why, based on trade data, Asian suppliers overall are more competitive and have captured more market share in the U.S. and EU markets in 2025 than “near-shoring” suppliers.

Additionally, China and Asia’s role in apparel sourcing could continue to evolve in 2026. I recently attended an industry event featuring textile and apparel manufacturers in Southeast Asian countries (ASEAN) and China. A few observations from the event stood out to me.

  1.  While the tariff was a top concern for most U.S. fashion companies, the conference mainly focused on facilitating investment and creating a more integrated, resilient, and sustainable textile and apparel supply chain in Asia. In other words, Asia-based textile and apparel suppliers did not seem panicked by the tariffs, nor do they believe the tariffs fundamentally challenge their long-term growth trajectory or hurt their export competitiveness.
  2. The Asia-based textile and apparel industry is becoming ever more global, mature, and advanced. Consistent with recent trade data, Asia-based fashion brands today commonly conduct global sourcing. They are investing heavily in new sustainable textile materials and digital technologies. They remain the largest buyer of the most sophisticated textile machinery in the world. Therefore, it is reasonable to expect that Asian suppliers as a whole will continue to dominate textile and apparel production and export into 2026 with no near competitors. 
  3. China’s leadership and influence within the Asia-based textile and apparel supply chain are increasingly visible. At the conference, ASEAN-based textile and apparel associations see China as a vital partner and source of investment. Through China’s Belt and Road Initiative (BRI), collaboration is extending from trade and investment to education and skills training. Overall, industry sentiment toward China in ASEAN differs significantly from the “decoupling” and “reducing China exposure” narratives that are gaining traction in the United States.
  4. An interesting question that I took away from the conference was whether China truly worries about losing market share in the U.S. and other markets for final apparel products. Perhaps not. Chinese industry leaders appear confident because they know that many Asian garment-producing countries remain heavily dependent on Chinese textile inputs, and many garment factories are funded or owned by Chinese investors. Given these dynamics, it will be interesting to observe how China’s confidence and its broader leadership role in Asia’s regional textile and apparel supply chain will continue to grow in 2026.

Opportunities in 2026

In 2026, we may see a significant increase in AI use in apparel sourcing. For example, fashion companies could use new AI tools to help optimize inventory levels and logistics, identify and evaluate new suppliers, and improve operational efficiency. AI may also play a more crucial role in supporting efforts around supply chain mapping, traceability, and sustainability data collection. Overall, we could see a more digitalized and data-driven sourcing process in the new year ahead.

On the other hand, in 2026, fashion companies could benefit from investing in and exploring new business models that support designing, making, sourcing, and selling sustainable apparel products. For example, a recent study of mine found that, by stock keeping units (SKUs) count, the number of clothing items made with recycled textile fibers increased by about 24% from 2024 to 2025 (August to October) in the U.S. retail market. Similarly, clothing items made with “regenerative” textile fibers surged by nearly 90% over the same period. These figures represent consumers’ increasing demand and fashion companies’ growing business interest in offering these products. New sustainability legislation, such as the Extended Producer Responsibility (EPR) at the state, regional, or international levels, will also create new incentives and pressure for fashion companies to revisit many of their current business practices. That said, balancing the sustainability benefits with other key sourcing metrics, such as costs, quality, and traceability, for these sustainable apparel products, will require ongoing efforts and improvements by fashion companies and their supply chain partners in 2026.

by Sheng Lu

How EU Fashion Companies Navigate Trump’s Tariffs (Updated November 2025)

This study aims to examine the impacts of the Trump administration’s escalating tariffs on the apparel sourcing and business practices of EU-headquartered fashion companies. Based on data availability, transcripts of the latest earnings call from about 10 leading publicly traded EU fashion companies were collected. These earnings calls, held between August and November 2025, covered company performance in the second quarter of 2025 or later. A thematic analysis of the transcripts was conducted using MAXQDA.

First, reflecting the global nature of today’s fashion apparel industry, many EU-based fashion companies also see tariffs as one of their top business concerns in the second quarter of 2025. However, overall, luxury fashion companies reported less significant tariff effects than fast-fashion retailers and sportswear brands. The result reflected luxury fashion companies’ distinct cost structure, supply chain strategies, and competitive factors, making them less sensitive toward tariff-driven sourcing cost increases.

Second, EU-based fashion companies generally regarded the rising sourcing costs and the resulting pressure on profit margins as the most significant impacts of Trump’s tariffs. Companies also noted that the tariffs’ financial impacts would be more noticeable in the coming months as more newly launched products became subject to the higher import duties. For example:

  • Adidas: “We already had the double digit hit when it gets to cost of goods sold already in Q2 in the U. S…the impact of these duties, if they are the way we have calculated them here, an increase in cost of goods sold of about CHF 200,000,000 (about $250 million USD).”
  • H&M: “Against that, we have the impact of the tariffs that will then, based on the tariffs we pay during Q3, a lot of those garments will be sold during Q4, and that’s when they affect our profit and loss.”

Third, EU-based fashion companies commonly adopted a sourcing diversification strategy to mitigate the tariff impact. Companies also increasingly look for vendors that can deliver speed, flexibility, and agility.  Furthermore, some EU companies have been strategically leveraging regional supply chains to meet the sourcing needs. For example:

  • Adidas: “We work with our suppliers who are mostly multi country…”
  • Hugo Boss: “Since our last update in early May, we have taken concrete steps to mitigate tariff-related impacts. Our well-diversified global sourcing footprint has a clear advantage in this regard. It enables us to swiftly adapt to changing conditions and optimize sourcing decisions.”
  • H&M: “We are working on how to increase the speed and reaction time in our supply chain. That’s a wide work that includes both, as we mentioned before, how we move production closer to the customer with what we call nearshoring or proximity sourcing, but it’s also working with a set of suppliers that can be much quicker and where they can support with a larger part of the product development process.”
  • C&A: “In the last quarter, we developed our logistics strategy to sustain C&A’s growth curve till 2030…This strategy was designed so as to bring greater speed and flexibility to our operational model through a more regionalized network, that is a network that is closer to the stores and major consumption centers, allowing us to have greater capacity to respond to the demands of each store.”

Fourth, like their U.S. counterparts, some EU fashion companies reduced their “China exposure” to lessen the impact of tariffs. Others establish a “China for China” supply chain due to perceived market opportunities there. For example:

  • Puma: “Our China exposure got reduced further for the Spring/Summer 2026 collection…The vast majority of our U. S. Imports originate from Asia, with Vietnam, Cambodia and Indonesia accounting for the majority…”
  • Adidas: “China is almost irrelevant for us because we have reduced the amount of China imports into the U. S. to only 2%…What we did is that we transferred the Chinese capacities to be mostly China for China…We have a more verticalized supply chain in China.”
  • Hugo Boss: “In particular, we have increased our inventory coverages in the U. S. And successfully rerouted product flows from China to other regions.”

Additionally, despite tariff-driven cost pressures, many EU-based fashion companies were cautious about raising prices, worried about losing customers in an overall weak market. Meanwhile, luxury fashion brands seem more comfortable raising prices than non-luxury brands. For example:

  • Adidas: “What kind of price increases could we take depending on the different duties, but there’s no decision on that…We are not the price leader, but we’d, of course, follow, a, what the market is doing, our competitor is doing and also, of course, look very closely what the consumer is accepting because in the end, it’s to keep the balance between all these factors.”
  • H&M: “That we do in the U.S., as we do in all other markets, and that leads to both price decreases and price increases to stay competitive. That’s an ongoing work. We are cautious about looking at the Q4 development in the U.S., given that we know we have already paid tariffs that will impact the gross margins as we look into the fourth quarter.”
  • Inditex (Zara): “With regards to the tariffs in the U.S. specifically, we have a stable pricing policy that we’re always talking about. Of course, all pricing activity, be it in the U.S. or any other geography, is primarily driven by commercial decisions, not financial ones. What we try to do in every market is maintain our relative position.”
  • Burberry: “19% of our revenues are from the US…We spent much of last year looking at the supply chain, looking at price elasticity…We took quite a surgical approach to price increases in the US, and…we really definitely understood where we had price elasticity there.”
  • Hugo Boss: “we will introduce moderate price adjustments globally with the upcoming spring 2026 collections, which will begin delivery towards the 2025. These steps aim to safeguard our margin profile while remaining aligned with broader market dynamics.”

by Sheng Lu

Interview with Modaes (Spain) about the Shifting Global Apparel Trade and Sourcing Patterns (November 2025)

Full interview in English HERE ; Spanish version HERE

Below is the interview summary

Q1. Since the pandemic, has the global fashion supply chain changed?

Key point: The pandemic taught fashion companies the importance of flexibility and agility in sourcing. Heavy reliance on China caused major disruptions during lockdowns, prompting companies to diversify their sourcing base and develop stronger supplier relationships to reduce various sourcing risks.

Q2. Is supply security now more important than price in sourcing decisions?

Key point: Security and sourcing are becoming more closely linked. Leading fashion companies understand that sourcing now requires balancing cost with other important factors such as flexibility, regulatory compliance, and risk management. New regulations related to sustainability demand increasingly detailed supply-chain documentation and transparency. Meanwhile, geopolitical tension between the U.S. and China further adds complexity to fashion companies’ sourcing decisions.

Q3. Are companies continuing to reduce the number of suppliers, and why?

Key point: Recent studies show that many fashion companies are diversifying sourcing beyond China, importing more from emerging supplying countries like Vietnam, Bangladesh, Indonesia, Cambodia, Pakistan, Egypt, and more. However, there are two divergent strategies: some brands expand their supplier base to spread risk and enhance capabilities in sustainable fibers, while others consolidate suppliers to strengthen partnerships with large vendors operating across multiple countries, many of which are still based in China.

Q4. Can the value chain function without China?

Key point: Not realistically. While China’s share of finished garment exports is declining, it still dominates in textiles raw materials. Even when apparel is made in other countries (like Vietnam and Cambodia), much of its fabric, investment, or ownership is Chinese. The newly released OECD data also show that about 30% of Southeast Asian apparel exports include Chinese content.

Q5. Which countries could take advantage of China’s declining role?

Key point: China’s dominance comes not only from its low costs but also from its capacity to produce almost any product category at large scale. To replicate this, companies need to use multiple sourcing locations — a “many-country model” instead of relying on just one. Therefore, diversification, rather than substitution, is the most practical approach. Firms seek to avoid over-dependence on any single country, especially given the volatility of tariffs and supply-chain disruptions.

Q6. Does “friendshoring” apply to fashion?

Key point: Politically appealing but impractical for apparel sourcing. The idea of friendshoring — trading only with “like-minded” nations — doesn’t fit with fashion’s global manufacturing system. Europe and the U.S. share values, but Europe lacks large-scale apparel production. Over 70% of U.S. apparel imports still come from Asia, where most countries are not formal U.S. allies. Therefore, political alignment cannot guide sourcing strategy in fashion; cost, capacity, and speed are more important.

Q7. Will geopolitics and the trade war reshape fashion sourcing in Europe or the U.S.?

Key point: Nearshoring remains a popular concept. European companies explore Eastern Europe and the Mediterranean; U.S. firms consider the Western Hemisphere and limited domestic production. Sustainability has emerged as the new opportunity for near-shoring. Fashion companies now aim to use more sustainable fibers in their clothing products. EU sustainability rules could also attract new investment to expand production in the EU. However, in general, small-sized firms need more resources and support to meet these high environmental standards, both to comply with the law and sustain their businesses.

Q8. Is de-globalizing production possible?

Key point: True de-globalization is unlikely. Instead, globalization is shifting toward greater transparency and accountability. Companies now need to track and report where products are made and how workers are treated, including the sourcing of raw materials. This encourages brands to work closely with their suppliers and promote stronger and strategic collaboration.

Q9. Are there enough incentives for production automation in fashion?

Key point: Yes — Automation provides a way to increase efficiency in high-wage countries like the U.S. With labor costs high and factories shrinking, machines and AI are being adopted to boost productivity and customization. Automation can also help cut down on overproduction — one of fashion’s major waste issues — by supporting made-to-order or small-batch manufacturing.

Q10. Why don’t we see full automation yet?

Key point: Cutting, sewing, and material handling today still require human labor, although factories increasingly use automated tools to boost productivity. Asian suppliers are upgrading equipment to handle smaller, faster orders. Automation is bringing back niche manufacturing (e.g., sock production in the U.S.) and supporting recycling efforts, such as sorting used garments. It helps lower minimum order quantities, matching production to uncertain consumer demand.

Q11. How can Europe maintain relevance amid the U.S.–China trade war?

Key point: Europe continues to be a key player in both textile and apparel manufacturing and consumption. Nearly half of the apparel in the EU is produced locally, often in high-wage countries like Italy, Germany, and France. Asian countries are looking for more market access to the EU because of higher tariffs imposed by the US (e.g., trade diversion). Europe also leads in sustainability and regulatory standards. Complying with EU rules often means meeting the highest global standards. Luxury branding (“Made in Italy/France”) remains highly influential, and the EU’s proactive trade agreements might even enable it to export textiles for processing in Asia, expanding supply chain integration.

Q12. Why hasn’t Africa become a viable textile hub yet?

Key point: Africa’s potential greatly relies on trade preferences like the African Growth and Opportunity Act (AGOA), which recently expired. Without duty-free U.S. access, U.S. companies are less likely to source there. However, the EU could help bridge the gap by forging partnerships for recycled textile materials and sustainable production. Regional collaboration could unlock Africa’s place in circular fashion supply chains.

For students in FASH455: Feel free to share your thoughts on any of the interview questions above. You may also challenge and debate any points raised in the interview and present your arguments.

Hot Button Apparel Trade and Sourcing Issues: Gen Z’s Perspective (October 2025)

As the fashion industry faces an unprecedented business and trade policy environment, hearing directly from Gen Z fashion majors—the next generation of both consumers and young professionals—has never been more critical.

In a new Just-Style mini series, students from FASH455 and the FASH department at the University of Delaware shared their valuable Gen Z perspectives on several hot-button apparel trade and sourcing issues as well as their vision for the future of the fashion apparel industry. Several findings are noteworthy:

First, like other consumer groups, Gen Z has felt the increasingly noticeable retail price hike driven by higher tariffs, and they are responding by reducing clothing purchases.  Compared to a survey conducted in April, nearly all Gen Z consumers now see higher price tags across a broad range of products, including necessities, outerwear, and footwear in the U.S. retail market. Notably, Gen Z consumers feel most strongly about the price hikes at fast fashion retailers—including Shein. Due to the perceived low quality and use of inexpensive textile materials, it is even more challenging for fast fashion brands to justify price increases. Our students who frequently thrift clothing also noted a price increase in the secondhand clothing market. As a warning sign to fashion companies, many surveyed Gen Z students say they plan to spend less this holiday season, or keep shopping “to a minimum” because of price increases.  For example,

  • Gabriella Krug, Fashion Merchandising and Management senior: As a shopper, I’ve adjusted by buying fewer items overall, checking sales racks more often, and using platforms like Depop and Poshmark to sell and buy trendy pieces. For the holidays, I think these price increases will push me, and most shoppers like me, to focus more on quality rather than quantity. I’ll definitely be taking advantage of Black Friday and Cyber Monday deals this year. Ultimately, tariffs could cause people to make more intentional and selective purchases this holiday season.
  • Cheyenne Weiss, Fashion Design & Product Innovation senior: While the higher tariffs have widespread effects on the fashion industry, I have personally noticed raised prices for outerwear and footwear. I noticed these two categories specifically as they are what I was shopping for going back to school and it is telling of how directly trade policy impacts consumers. The effects of the tariffs are hitting close to home, and I would feel most frustrated to see loungewear and athleisure categories rise in price. While these areas seem to already be feeling the effects of raised tariffs, it would be hard as a consumer to continue purchasing these items if tariffs keep rising, considering these are the fashion categories I buy from the most often. As a shopper, the higher prices discourage me from going out and purchasing new clothing.
  • Skye Johnson, Fashion Merchandising and Management senior: I have noticed that prices are rising among all types of clothing. In particular, I have heard that Fast Fashion retailers like H&M or even Shein have increased their prices significantly. While I personally do not shop at fast fashion retailers like Shein, I’ve seen the impact through school research projects and conversations with friends. This is frustrating because these fast fashion items are made with very cheap materials like polyester and nylon.
  • Julia Brady, Graduate Student studying Fashion and Apparel with a focus on Sustainability: I mainly shop using online resale sites, such as Depop, and just enjoy browsing higher-end online consignment stores, like Vestaire and theRealReal, for secondhand designer deals. I have seen fewer deals on the site and more high-priced secondhand designer items… Even on Depop, international listings are higher than normal. The category I would be most frustrated to see prices rise in would be footwear… I also expect to buy holiday gifts from local artisans and local stores, due to higher quality and (hopefully) decreased tariff impact.
  • Nadia Grosso, Fashion Merchandising and Management senior: I’ve noticed myself becoming even more price-sensitive when shopping because of the rising prices, so I’m always looking to find the best deal to stretch my budget as much as I can. Overall, I think shoppers are trying to limit their spending as much as possible, and being more cognizant of prices when choosing what to purchase and who to purchase from. As a result, come holiday shopping time, I might be more inclined to shop at discount retailers or even decrease how much I purchase compared to previous years.

Second, Gen Z fashion majors view globalization and international trade as generally beneficial for the fashion industry. At the same time, they emphasize the need to enhance sustainability and social responsibility in the global apparel trade. For example, while most survey respondents supported leveraging apparel trade to promote economic development in developing countries, they also stressed that trade volume alone should not define success. Instead, many highlighted the importance of ensuring that garment workers in developing countries directly benefit from trade and Western fashion brands and retailers have a responsibility to help make this happen. For example,

  • Emilie Delaye, Master’s student in fashion and apparel studies: I believe that it is almost virtually impossible to move manufacturing fully back into the US. Nearshoring could really help sustainability (as fewer emissions would be released), but nearshoring would require investment and savvy trade deals to ensure that many different kinds of products can be produced there. I don’t really think it is that important that the US maintains a “strong” textile and apparel sector. As we know from the innovation or economic development timeline, the textile and apparel sector is an entry point for less developed economies. It could actually be perceived as a positive that we aren’t largely in this market. I think that there are other more critical sectors to focus on for the US. Plus, we simply do not have the skilled labor or machinery needed to do this. I support the leveraging of the clothing trade to support economic development in the countries that need it. I believe that if done sustainably and socially responsibly, the apparel sector could help millions of individuals in these countries.
  • Abigail Loth, Fashion Merchandising and Management senior: As a consistent consumer in the US fashion industry, I believe that globalization and international trade is vital for our success. Not only does it keep trends fresh, globalization and international trade encourage styles to remain diverse and costs to be cheap… Maintaining a strong domestic textiles and apparel sector in the US is also extremely important. This is because it provides an abundance of jobs/opportunities, innovation and sustainability practices. So, in order to leverage the clothing trade and support workers in developing countries as ethical sourcing and fair labor practices help ensure that globalization benefits more than just corporations.
  • Ekaterina Forakis, Fashion and apparel studies 4+1 graduate student: Globalization and international trade are crucial aspects of the U.S. fashion industry. It is these that keep the U.S. fashion industry running. Trade theory explains why globalization benefits countries like the U.S. and allows them to focus on textile manufacturing, one of the country’s strong suits. Higher tariffs and import restrictions are not necessary to maintain U.S. manufacturing because the U.S. is already a top textile exporting country and does not specialize in apparel production. The country’s capacity for automation is what makes it reliable in the textile sector. Automation allows for more standardized production of textiles which are necessary for developing countries to produce apparel.
  • Emma Lombardi, Fashion Design and Product Innovation senior: I view globalization and international trade as a double edged sword for the U.S. fashion industry, because on the one hand, while it doesn’t benefit the creation of jobs in rural areas that many covet, it also shifts the emphasis towards more sophisticated industries in technology development and innovation both in mechanical and textile sectors.
  • Julia Brady, Graduate Student studying Fashion and Apparel with a focus on Sustainability: I think tariffs and import restrictions are necessary, but not just to protect U.S. domestic manufacturing. Tariffs could help regulate the amount of toxic chemicals along the textile manufacturing value chain. An alternative route for the U.S. to take would be to scale up flax for fibers to be used in domestic textile manufacturing. Perhaps tariffs will force companies and the federal government to invest in agricultural advances in this field…I would never want to advocate taking away work in developing countries; however, for the sake of our environment, we may need to shift the way the fashion supply chain currently operates. It is important to me that the U.S. maintains a strong textiles and apparel sector because we are a big part of the problem. We must take control over the way we consume and dispose of textiles. There could be so many opportunities for economic growth if we shift toward domestic manufacturing, prioritizing the use of materials we already have.

Third, associated with the debate on the future of textiles and apparel “Made in the USA,” most Gen Z fashion majors show little interest in factory jobs. On the one hand, unlike most developing countries, today’s U.S. fashion industry provides Gen Z fashion majors with many exciting and promising non-manufacturing job opportunities, ranging from apparel design, product development, sourcing, trade compliance, and merchandising to marketing. By contrast, factory jobs are often perceived as “low paid,” “repetitive,” and “poor working conditions.”  Our Gen Z fashion majors particularly emphasized that their preferred employers should provide both financial and career progress opportunities, and they want to see keywords such as “innovation,” “sustainability,” “room to grow,” and “inclusiveness” associated with their future jobs. In other words, to attract more Gen Z workers to factory jobs, companies need to do more than just offer competitive pay. For example,

  • Gabriella Krug, Fashion Merchandising and Management senior: At this point in my career, I have not pursued an interest in textile or apparel manufacturing or factory-related jobs. My internships have exposed me to different sides of the industry…That said, I think my generation could see these roles as more appealing if companies focused on innovation, sustainability, and clear opportunities for growth. For example, if factories showcased their role in a circular fashion and created a more modern, flexible work environment, I think more Gen Z talent would be drawn in since we’re motivated by making a positive impact. Personally, I’m most interested in jobs that mix creativity with business—like sales, buying, or trend forecasting. When it comes to an employer, I value opportunities to learn and grow, strong mentorship, and a culture built on collaboration and inclusivity.
  • Cheyenne Weiss, Fashion Design & Product Innovation senior: I am not personally interested in pursuing a career in textile or apparel manufacturing as I see myself in a more creativity-based position. I feel as though my skills in fashion would be better suited for a role where I’m working directly with design and developing the fit and aesthetics of garments. Factory-related jobs in fashion could become more appealing to my generation if more rising fashion professionals knew about the opportunities that are available… When considering the qualities of an employer that I would want to work for, an important factor for me is a growth mindset. I value being able to learn and adapt as the industry evolves and I would want my employer to share my same persistence to always be learning and bettering the quality of work I can produce.
  • Skye Johnson, Fashion Merchandising and Management senior: I am not interested in pursuing careers in textile and apparel manufacturing or factory related jobs. However, I completely respect the importance of these roles in our fashion industry. I feel that my skills or career goals do not align with these jobs, but there could definitely be ways to make it more appealing to Gen Z. For example, offering safer working conditions, competitive pay, clear paths for professional growth, etc… When considering an employer, I value a workplace that aligns with my values, offers an inclusive environment, open communication, creative freedom, and room to grow in the company. I want to feel like I belong and am making an actual impact where I work.
  • Abigail Loth, Fashion Merchandising and Management senior: I personally do not have any interest in pursuing a career in textile or apparel manufacturing and factory-related jobs. These jobs consist of heavy hands on labor, limited creativity and repetitive daily tasks. The job is very cookie-cutter and has limitations for growth and opportunity. In order to make these types of factory jobs more appealing to our generation, the employers should provide safer working conditions, more money, and a sense of change/development in the everyday job. If factory jobs allowed more flexibility for creative thinking and alterations, they would appeal more to Gen Z.
  • Julia Brady, Graduate Student studying Fashion and Apparel with a focus on Sustainability: I am interested in pursuing a career related to textile and apparel manufacturing. Specifically, I would love to work towards a more socially responsible fashion industry. I could see myself working for a textile recycling plant in the U.S.; I expect more to be popping up over the next decade. If the factories were focused on green engineering and diverting textile waste, this might be another attractive core value of a potential future employer. I would be more inclined to work a factory job if the conditions in the factory were regulated and protective of the workers’ health. Additionally, if the employer was prioritizing the use of natural materials combined with textile recycling outputs, this would be very appealing to me as a prospective employee.

Fourth, Gen Z fashion majors show a high awareness of AI and are open to increasing its use in the fashion industry. Specifically, our Gen Z students believe that AI can be a powerful tool widely adopted by fashion companies, such as supporting apparel sourcing decisions, generating designs, and conducting data analysis and forecasting. Many also envision bold, creative applications of AI, such as optimizing secondhand clothing use or dynamically altering garments’ colors and textures based on weather conditions or consumers’ moods. These findings underscore the growing importance of deliberately integrating AI into fashion education and strengthening collaborations between industry and academia. For example,

  • Emilie Delaye, Master’s student in fashion and apparel studies: I think that AI could help understand and simplify the complex supply chains we have. Perhaps by incorporating AI into sourcing decisions, it could help determine the most efficient and eco-friendly path for the garment.
  • Gabriella Krug, Fashion Merchandising and Management senior: If there were no limits in terms of technology or resources, I would love to see AI used to create a truly circular fashion system. Garments would be designed with little to no waste from the very beginning with AI predicting the most sustainable production methods. Also, I think AI should account for each garment’s end-of-life by tracking how items can be reused, recycled, or repurposed.
  • Skye Johnson, Fashion Merchandising and Management senior: I still feel that AI will not be able to completely take over in the fashion industry, we still need that human touch. That human aspect is what makes the industry go round, especially when it comes to designers…If I could pick a bold AI-driven innovation to see in the fashion industry, I would love to see garments that change color or texture based on your mood or the weather. The AI technology could read your personal style and predict what looks best on you. That would definitely take years to make, but it would further blur the lines between fashion, technology and art.
  • Abigail Loth, Fashion Merchandising and Management senior: I would love to see AI-driven innovation that would be able to make custom designs depending on preferred colors, style, size, or shape and deliver it based on preferences of style and sustainability.
  • Nadia Grosso, Fashion Merchandising and Management senior: AI can be a helpful tool to analyze data and make recommendations on how to apply its findings to real-world situations. Especially with the uncertainty surrounding changing prices and geopolitics, AI could be implemented to help fashion companies navigate difficult sourcing decisions and manage their complex supply chains. I would also love to see AI be implemented more to drive sustainability initiatives such as reducing waste within production or even assisting with the discovery and development of more sustainable materials. However, I don’t think AI can fully replace human intelligence and creativity, so it’s important for it to be used as a tool and not as a replacement.

Additionally, the results show that Gen Z fashion majors overwhelmingly support the increased use of recycled textile materials in clothing and view it as an important opportunity to address the textile waste problem. However, as consumers, they still expect such products to remain financially affordable, match the quality of non-sustainable options, and look stylish. Additionally, with greater knowledge and awareness of sustainability, Gen Z consumers expect fashion companies to provide more transparency regarding their recycling practices and price structures (i.e., what they are actually paying for). This requires fashion companies to continue to improve their supply chain mapping and traceability in the era of textile recycling. For example,

  • Emilie Delaye, Master’s student in fashion and apparel studies: The (recycled) garments currently on the market are very expensive and do not appeal to my personal style…And it is very important for fashion companies to provide clear sustainability information. I think providing information on the cost breakdown would be valuable to see and ensure that the money is distributed more evenly.
  • Gabriella Krug, Fashion Merchandising and Management senior: Yes, I do care about clothing made from recycled textile materials because it feels like a step in the right direction and it makes me feel like I am making a more thoughtful choice as a consumer…What makes these products most appealing to me is the mix of style and transparency. Especially with Gen Z, the culture is shifting more and more toward eco-conscious consumers, now with the help of Depop, ThredUp, and Poshmark. These platforms give people an easy way to step into the world of sustainable fashion. For me, I want to know that the clothing looks and feels just as high-quality as non-sustainable options, but I also don’t want to feel like I’m overpaying just because it’s labeled as eco-friendly…I want brands to be upfront about what percentage of a garment is actually recycled and how it was made
  •  Skye Johnson, Fashion Merchandising and Management senior: For me, the appeal of recycled or sustainable fashion products comes from a combination of style, price, and brand transparency. I believe it is very important that fashion companies provide clear sustainability information and have the efforts and data to back it up… Obviously, no brand is perfect, but when I see a brand putting in the work to do better, I respect them a ton more.
  • Nadia Grosso, Fashion Merchandising and Management senior: Fashion brands need to do more to educate their consumers and highlight the importance of sustainability, while also incorporating it as a value into all of their business practices. I think that we can make sustainable and recycled products more appealing to consumers by being transparent and educating them on their importance. Fashion brands are becoming increasingly aware that providing clear sustainability and sourcing information to their consumers is necessary to gain their trust and loyalty, especially as a growing number of consumers are considering these practices as influencing factors to make purchases.

FASH students who contributed to the series include:

  • Gabriella Krug, Fashion Merchandising and Management senior
  • Emilie Delaye, Master’s student in fashion and apparel studies
  • Cheyenne Weiss, Fashion Design & Product Innovation senior & 4+1 graduate student
  • Skye Johnson, Fashion Merchandising and Management senior
  • Julia Brady, Master’s student in fashion and apparel studies
  • Abigail Loth, Fashion Merchandising and Management senior
  • Nadia Grosso, Fashion Merchandising and Management senior
  • Ekaterina Forakis, Fashion and apparel studies & 4+1 graduate student
  • Emma Lombardi, Fashion Design and Product Innovation senior

Explore more:

Updated Impact of Increasing Tariffs on U.S. Fashion Companies’ Sourcing and Businesses

This study aims to examine the impacts of the Trump administration’s escalating tariffs on U.S. fashion companies’ apparel sourcing practices. Based on data availability, transcripts of the latest earnings calls from about 30 leading publicly traded U.S. fashion companies were collected. These earnings calls, held between August and October 2025, covered company performance in the second quarter of 2025 or later. A thematic analysis of the transcripts was conducted using MAXQDA.

Key findings:

First, U.S. fashion companies reported a more significant impact of the increasing tariffs on their financial performance as the tariff increase expands from China to other countries. Many companies regarded tariffs as one of their top-most pressing external challenges to profitability in 2025, especially in the second half and beyond.  For example:

  • G-III Apparel: “We expect the total incremental cost of tariffs to be approximately $155 million, up from the $135 million original estimate, and this is based on the latest tariff increases implemented for Vietnam, India and Indonesia, among others.”
  • American Eagle: “On tariffs, yes, we are providing the guidance here for the third and fourth quarter. About $20 million of impact from Q3. $40 million to $50 million in Q4. So that will pressure gross margin a bit.”
  • Hanesbrands: “When you think about tariffs and the impact on our business, first of all, we won’t be really experiencing that cost until Q4 because of the inventory that we have and the way cost flows off of our balance sheet.”
  • Victoria’s Secret: “Our projected net tariff impact of $100 million in 2025 is up $50 million versus our assumption embedded in our previous guidance. With approximately $10 million of net tariff impact already recognized in the first half of the year, our guidance assumes approximately $20 million of net tariff pressure in the third quarter with $70 million impact in Q4.”
  • Tapestry: “We are facing greater than previously expected profit headwinds from tariffs and duties, with the earlier-than-expected ending of de minimis exemptions being a meaningful factor. In aggregate, the total expected impact on profitability this year from tariffs is $160 million, representing approximately 230 basis points of margin headwind.”
  • Carter’s: “We’ve assessed the higher incremental tariffs, which have already been implemented, an additional 10% duty for all countries and higher incremental duties for products from China, Vietnam and Indonesia. Relative to a few months ago, we’re preparing for a world with higher and more permanent tariffs above the over $100 million in duties, which we have paid historically. Our estimate of the additional baseline tariffs is that it would represent a gross additional tariff amount between $125 million and $150 million on an annualized basis.”

Second, despite the higher tariff burdens, most U.S. fashion companies still try to avoid across-the-board price hikes due to concerns about losing consumers. Instead, most companies opt for selective price increases, value-based pricing, and closely monitor consumers’ price sensitivity. However, price increases could be more noticeable down the road. For example:

  • Oxford industries: “We’ve not done sort of an across-the-board approach to pricing. We’ve really looked at it on an item-by-item basis and balanced the need to protect our margins and try to recover some of the tariff impact with not wanting to get too far ahead of ourselves because that tariff number…as we get into spring ’26… And on average, that’s led to sort of low to mid-single digit or low mid-single-digit price increases…we’re just being very cautious about increasing the price too much before we really know where things are settled out.”
  • URBN: “our pricing strategy…is really to look at some gentle price increases where we feel like there’s the value that contributes to that. So making sure that we’re protecting some of the opening price points that the customer counts on and some programs that we know drive a lot of volume…Recognizing the value equation is really important to all of our consumers.”
  • TJX: “I think you’re gonna see a more of a little bit of a gradual increase in pricing as the tariffs come in…I don’t think you’ll see step all of a sudden Right. With the tariffs set,because I don’t wanna, I think, turn off customers immediately by seeing a dramatic price shift. So I think they might they might they might absorb it initially for a little bit, and eventually, they’ll get there.”
  • Columbia Sports: “We expect higher prices for many consumer goods will negatively impact consumer demand…In fall ’25, we’re working with our retail partner to deliver value to consumers and keep inventory and dealer margins healthy. As a result, we’re not making any significant price changes to our fall ’25 product line and expect to absorb much of the incremental tariff costs this year…Our goal is to offset higher tariffs over time through a combination of actions, including price increases, vendor negotiations, SG&A expense efficiencies and other mitigation tactics.”
  • Ralph Lauren: “The big unknown sitting here today is the price sensitivity and how the consumer reacts to the broader pricing environment and how sensitive that consumer is. And that’s what we’re watching very closely as we head into the second half.”
  • Ross stores: “Some of the India tariffs, especially if the 25 goes to 50…I think that you’ll see this go into next year, and I think we would expect to see price increases. And — but over time…we think it will reach equilibrium, and it will be business as usual.”
  • Burlington stores: “we are seeing that competitors are taking up retail prices. So far, though, I would say that those price increases have been quite selective and quite restrained…Part of it may just be the time lag between imports arriving in the country and those goods showing up in stores. But also my sense is that wholesalers and retailers have been reluctant to make decisions on raising prices until they know what the final tariff rates are going to be. Now it does feel like there is more clarity on this now than there was a couple of months ago. So it wouldn’t be surprising if retail prices were to go up across the industry in the back half of the year. Now of course, we know that our customer is very, very price sensitive.”
  • VF Corporation: “we have actions in place to mitigate the tariff impact through sourcing savings and pricing actions that will take effect later this year.”

Third, while U.S. fashion companies overall continue to reduce their apparel sourcing from China amid the current tariff and geopolitical tensions, some companies still regard China as a viable sourcing base given its many unique advantages, such as speed to market, production efficiency, and well-developed supply chain infrastructure. For example:

  • Carter’s Inc: “We’ve meaningfully reduced our exposure to China manufacturing over the last number of years. And now, as summarized here, our largest countries of origin are Vietnam, Cambodia, Bangladesh, and India.”
  • Abercrombie & Fitch: “Our approach and underlying principles for tariff mitigation remain unchanged, supported by a deep playbook and experience. We continue to expect China sourcing share in the U.S. will be in the low single digits for the year.”
  • Steve Madden: “Since the last call…We have moved certain production for fall back to China, where we felt it would be difficult to ensure on-time delivery, appropriate product quality and/or reasonable pricing in an alternative country. For fall 2025, we currently expect to source approximately 30% of our U.S. imports from China, down from 71% for the full year 2024..
  • Oxford industries: “With the recent tariff increases announced during the second quarter, including increased tariffs in countries like Vietnam and India that were included as part of our shift away from China, largely offset by the mitigation efforts we have undertaken, including accelerated inventory receipts and quickly shifting our sourcing network.”
  • American Eagle: “If you start with all the country of origin remixing…China where we know we were at a higher penetration coming into the year is mid-single digit now in a full year.”

Fourth, establishing a geographically diverse sourcing base continues to be a crucial strategy employed by U.S. fashion companies to mitigate tariff impacts and policy uncertainty. U.S. fashion companies are also intentionally adding speed, flexibility, and agility to their sourcing base and supply chain. However, given the complex sourcing factors fashion companies have to consider, plus the broad scope of “reciprocal tariffs, there is no clear winner. For example:

  • Kohl’s: “We have a diversified sourcing strategy from a country standpoint. We’re not heavily reliant on any one particular country, and we have the flexibility and agility to actually move production to other countries if necessary.”
  • PVH: “We work closely with an established network of global sourcing partners across more than 30 countries, and we continue to leverage our deep long-standingrelationships to further optimize our sourcing and production costs.”
  • American Eagle: “If you start with all the country of origin remixing…India is small for us. Rebalancing some things out of Vietnam.”
  • Steve Madden: “we were focused on moving a lot of product to Brazil. We’re going to have to wait and see what happens. I think that really goes not just for Brazil, but for a lot of the countries that we work with. So we’ve tried to create a more diversified sourcing footprint. And — but there’s obviously a lot of uncertainty still about where the ultimate tariff rates will land by country. And so we’re going to have to wait and see what happens and then react accordingly. That’s all we can do.”
  • Hanesbrands: “when you think about tariffs and the impact on our business…not only do you have the Q4 impact, but you have to think about those other offsets about meaningful U.S. content that we have in our products that are exempt from reciprocal, the good East-West balance that we have in our supply chain…”
  • Land’s End: “With regard to sourcing…we have been intentionally repositioning our sourcing network to better serve the business we are building leading to a more balanced supply chain that enables us to bring new solutions to customers with more speed and frequency throughout the year. For example, our licens epartners are becoming part of our sourcing network…By tapping into the full breadth of our sourcing matrix, we are able to swiftly and strategically reposition fabric and manufacturing as tariff conditions evolve.”

Fifth, as part of their tariff cost mitigation strategy, many U.S. fashion companies have been strategically but cautiously building preemptive stock, adopting a data-driven approach to optimize inventory, and simplifying product assortment. For example:

  • Levi’s: “And for Q4, we declared a dividend of 14¢ per share, which is up8% to prior year. We ended the quarter with reported inventory dollars up 12%, driven by purposeful investment ahead of the holiday and higher product cost than a year ago due to tariffs. In unit terms, inventory was up 8% versus last year. As of today (October 9, 2025), we have 70% of the product in the US needed for holiday.”
  • Ralph Lauren: “So we feel good about our inventory levels as we head into the fall season. So we ended Q1 (2025), as you know, with inventories up 18% versus Q1 of last year (2024)…if you think about sort of our Q2 revenue guide of up high single digits, relates to the strategic acceleration of largely core inventory receipts into the U.S. in Q1 during the tariff pause period…So if you back out that tariff-related strategic pull up, our inventory growth is actually a little behind our double-digit top line growth for Q1 and right in line with our expected high single-digit top line growth for next quarter, Q2. And…for the year to go, we expect inventories to moderate as we move throughout the fiscal year, and we plan on ending fiscal ’26 with levels generally in line with demand.”
  • PVH: “Inventory at quarter end (Q2, 2025) was up13% compared to Q2 last year (2024), including a 1% increase due to tariffs, and reflects a planned improvement compared to up 19% in Q1.”
  • Hanesbrands: “we’re leveraging advanced analytics with the use of AI to drive operational improvement around the globe, including inventory and assortment management as well as demand planning and forecasting.”
  • Tapestry: “We’re bringing more innovation to the assortment while we streamline our offering, reducing handbag styles by over 30% by fall, allowing us to stand behind our big ideas with clarity and intention.”

by Sheng Lu

FASH455 Exclusive Interview with Nicole Bivens Collinson, Managing Principal and Practice Leader of International Trade and Government Relations, Sandler, Travis & Rosenberg, P.A.

About the interview

When learning about apparel sourcing and trade, our students often notice how much they are affected by trade policies and regulations—from tariffs, and something called “de minimis” to UFLPA. These issues are not only critical for fashion companies but can also be quite technical.

We are fortunate to have Nicole Bivens Collinson, Managing Principal and Practice Leader of International Trade and Government Relations of Sandler, Travis & Rosenberg, P.A. (ST&R), a true expert in trade policy and the legal aspects of trade, join us. In the interview, Nicole clarified key U.S. trade rules and provided valuable insights into their apparel sourcing and trade implications, including:

  • What is a tariff, and why is it a big issue for US fashion brands and retailers?
  • Why have the so-called IEEPA “reciprocal tariffs” imposed by the Trump administration so far this year raised so many concerns?
  • What does the term “transshipment” mean in international trade? And why did this issue emerge in the context of higher tariffs this year?
  • What is the “20% US content” rule and its implications for fashion companies?
  • What is “tariff engineering”? Is it legal or illegal? How have fashion companies used it to mitigate the tariff impacts, potentially?
  • What is de minimis? Why was it created, and then became controversial? Since the “de minimis” rule was officially terminated recently, what impacts could we expect now? 
  • What is the Uyghur Forced Labor Prevention Act (UFLPA) and what does it aim to do? How has the implementation of the UFLPA affected U.S. fashion companies’ apparel sourcing?
  • For fashion students interested in working in trade compliance, trade policy, or the legal aspects of the fashion industry, what steps can they take to get started?

About Nicole Bivens Collinson

Nicole Bivens Collinson is the Managing Principal and Practice Leader of International Trade and Government Relations with Sandler, Travis & Rosenberg, P.A. (ST&R). Nicole is a commentator on trade matters on MSNBC, NPR, and BBC the producer of the Two Minutes in Trade podcast.

Nicole has nearly 40 years of experience in government and public affairs and lobbying. She prepares countries, companies, and associations for negotiations with the United States on free trade agreements, trade and investment agreements, labor disputes, and preferential trade programs.

Prior to joining ST&R, Nicole served as assistant chief negotiator for the Office of the U.S. Trade Representative, responsible for the negotiation of bilateral agreements with Latin America, Eastern Europe, Southeast Asia, the Sub-Continent, and Africa. She also served as a country specialist in the International Trade Administration at the Department of Commerce, where she was responsible for the preparation of negotiations on specific topics between the U.S. and Latin America, Eastern Europe, China, and Hong Kong as well as the administration of complex textile agreements.

Nicole holds a master’s degree in international relations from The George Washington University and a triple bachelor’s degree in political science, European studies, and French from Georgetown College. She also studied at the Université de Caen in France.

Nicole is past chair of the Women in International Trade Charitable Trust, past president of Women in International Trade, an advisory board member of America’s TradePolicy.com, treasurer and board member of the Washington International Trade Association, and a member of the Washington International Trade Association Foundation and Women in Government Relations. She serves on the board of trustees for Georgetown College and is the past executive director for the U.S. Hosiery Manufacturers Coalition, the U.S. Apparel Industry Coalition, and the U.S. Sock Distributors Coalition.

About Katie Yasik (moderator)

Katie Yasik is a master’s student & graduate instructor in Fashion and Apparel Studies (FASH) at the University of Delaware (UD). Katie graduated from UD & FASH with a B.S. in Fashion Design and Product Innovation & Sustainable Apparel minor. Driven by her strong passion for sustainability, she interned with the Worldwide Responsible Accredited Production (WRAP) in Spring 2024.

FASH455 Exclusive Interview with Shannon Brady, Import and Product Operations Manager at LoveShackFancy

About the interview

In this exclusive FASH455 interview, we are thrilled to welcome Shannon Brady, Import and Product Operations Manager at LoveShackFancy and a proud UD & FASH alum, to share her experiences navigating global apparel sourcing for fashion students. Shannon offered first-hand insights into the latest sourcing trends in the fashion apparel industry and reflected on her career journey in sourcing and trade. Specific topics covered in the interview include:

  • Apparel sourcing process in general
  • The current U.S. tariff situation and its impacts on apparel sourcing
  • Why do apparel sourcing orders still mostly go to Asia?
  • Outlook for apparel on-shoring and near-shoring
  • Sustainability and sourcing in practice
  • Career opportunities in apparel sourcing and trade

Note: This interview is for informational purposes only and reflects Shannon’s personal perspectives. What was shared in this interview should not be taken as, and does not constitute, official policy, position or guidance from LoveShackFancy.

About Shannon Brady

Shannon Brady is the Import and Product Operations Manager at LoveShackFancy. With over four years of experience in product development and sourcing, she specializes in driving vendor performance, optimizing supply chains, and leading cross-functional initiatives. Before her current role, she worked for the U.S. Fashion Industry Association in Washington, D.C., and then joined Party City as a Sourcing Operations Manager.

Shannon graduated magna cum laude from the University of Delaware with a B.S. in Fashion Merchandising. She was a 2018 UD summer scholar, and her co-authored case study Managing the used clothing trade  was published in the Bloomsbury Fashion Business Cases.

About Emilie Delaye (moderator)

Emilie Delaye is a master’s student & graduate instructor in Fashion and Apparel Studies at the University of Delaware, with a specific interest in supply chain, global sourcing, and sustainability. 

Patterns of U.S. Apparel Imports (updated September 2025)

First, as a result of the IEEPA reciprocal tariff, the average tariff rate for U.S. apparel imports (HS Chapters 61 and 62) reached 26.4% in July 2025, marking a new high in decades (note: was 25.4% in June, 23.8% in May and 20.2% in April 2025), and a substantial increase from 14.7% in January 2025, prior to Trump’s second term. Even apparel imports from traditional U.S. free trade agreement partners, such as CAFTA-DR members, now have to be subject to about 10% applied tariffs. And apparel imports from Mexico still enjoyed a relatively low 1.6% tariff rate in July 2025. [Check the applied US apparel import tariff rate here]

Second, U.S. apparel imports fell in July 2025, negatively impacted by the hiking of tariffs and consumers’ growing hesitancy in clothing spending amid uncertainty about their household financial outlook. Specifically, U.S. apparel imports in July 2025 decreased by 3.0% in value and 5.2% in quantity from a year ago, indicating both an overall shrinking import demand and a more notable import price increase. [Check U.S. apparel import index here]

Statistics also show that after removing the seasonal factor, the average U.S. apparel import price went up by nearly 3% from April to July. This trend could become even worse in the coming months as more countries face even higher “reciprocal tariffs” starting from August 2025. However, the average U.S. apparel retail price has not significantly increased, likely because fashion companies fear losing sales at a time when consumers’ clothing spending is already weak. [Check the U.S. clothing retail price index here]

Third, continuing the trends from previous months, U.S. apparel imports from China again fell sharply in July 2025. Facing nearly 50% tariff rates—much higher than those applied to other sourcing countries—U.S. apparel imports from China decreased by 38.4% in value and 27.3% in quantity in July 2025 from a year ago. As a result, in value, China’s market share fell to just 15.6% in July 2025 (was 24.6% in July 2024), significantly lower than Vietnam’s 22.1% (was 19.1% in June 2024). In other words, it may signal a new era where China is no longer the top source of U.S. apparel imports. [Check market shares in U.S. apparel imports here]

Fourth, while Asia as a whole still dominates, trade data suggests more notable trends of sourcing diversification. In July 2025, about 72.9% of U.S. apparel imports came from China, far exceeding the Western Hemisphere (14.8%) and the rest of the world (12.4%). However, Asia’s market share in July 2025 was slightly lower than 74.7% a year ago, suggesting that more imports came from other regions. For example, at the country level, US apparel imports from several emerging Asian suppliers and those in the Middle East and Africa enjoyed fast growth, including Vietnam (up 12.5%), Cambodia (up 25.2%), Pakistan (up 14.7%), Jordan (up 21.6%), and Egypt (up 30.3%).

Meanwhile, U.S. apparel imports from India in July 2025 also increased by over 15%, although the newly imposed higher tariffs on India could alter the trend in the next few months.

Additionally, there is still no evidence that Trump’s tariff policy has meaningfully boosted nearshoring from the Western Hemisphere. On the contrary, in July 2025, U.S. apparel imports from Mexico grew by just 0.5%, despite the significant tariff advantage offered to USMCA-qualifying products. Similarly, imports from CAFTA-DR members decreased by 2.7%. The results revealed the adverse effects of uncertainty in the Trump administration’s tariff policy on encouraging long-term sourcing and investment commitment to the region.

(note: this post is not open for discussion)

By Sheng Lu

FASH455 Video Discussion: The Lesotho Garment Industry in the Shadow of Trump’s Tariffs

Discussion questions: (for students in FASH455, please address at least two questions below in your response. There is no need to repeat the question, but please mention the question #)

  • #1 How do you see the importance of the garment industry to Lesotho—economically, socially, and politically?
  • #2 Why and how could the 15% additional tariff have a significant impact on Lesotho’s garment industry?
  • #3 What responsibilities do U.S. fashion brands and retailers have toward Lesotho in the situation described in the videos?
  • #4 If you were a U.S. garment worker, would you support more favorable trade terms for Lesotho? Why or why not?

Background

  • According to the World Trade Organization (WTO), textiles and apparel accounted for 56.6% of Lesotho’s manufactured goods exports in 2023.
  • UNComtrade data shows that between 2023 and 2024, about half of Lesotho’s apparel exports went to the United States, its largest export market. Other countries in Sub-Saharan Africa (SSA) made up an additional 44% of Lesotho’s apparel exports.
  • Industry sources further indicate that between January 2024 and July 2025, about 60% of apparel labeled “Made in Lesotho” for sale in the U.S. retail market were tops, including 41% of T-shirts. All of these clothes targeted the mass and value market segments, and they were typically priced even lower than those “Made in Bangladesh.”
  • The African Growth and Opportunity Act (AGOA), a trade preference program enacted in 2000, has played a critical role in supporting Lesotho’s apparel export to the U.S. market.
  • Data from the Office of Textiles and Apparel (OTEXA) under the U.S. Department of Commerce shows that U.S. apparel imports from Lesotho totaled $151 million, or 0.19% of total U.S. apparel imports, in 2024. Notably, all of these imports claimed the AGOA duty-free benefits, and 96.8% were entered under the “third-country fabric” provision, which allows least developed countries (LDCs) like Lesotho to use textile raw materials sourced from third countries.

[Discussion is closed for this post]

FASH455 Exclusive Interview with Karin De León, Investment and Promotion Director, Apparel and Textiles Association of Guatemala (VESTEX)

About Karin De León

Karin De León has been working in the textile and apparel sector in Guatemala for more than 25 years, promoting the development of the industrial cluster, participating in the creation of strategies, supporting the strengthening of the supply chain, and attracting investment.

As part of her role at the Apparel and Textile Association of Guatemala (VESTEX), for 10 years she held the position of Executive Director of CECATEC-RD (Central American and Dominican Council of Clothing and Textiles), the entity that integrates textile & apparel industry associations of Central America and the Dominican Republic and which is responsible for coordinating the inter-institutional relationship with public and private entities of the United States of America, Mexico and Colombia mainly.

From 2020 to the beginning of 2022, she served as Chief of Staff of the Ministry of Economy of Guatemala and later became General Coordinator of the National Competitiveness Program (PRONACOM), a government entity responsible for promoting the country and attracting investment.

Karin is currently VESTEX’s investment and promotion director, and representative of Guatemala in CECATEC-RD. She coordinates the inter-institutional relationship with government entities of the United States (such as the United States Trade Representative and the Department of Commerce) as well as private institutions mainly related to the United States, Mexico, and Colombia.

Sheng: Can you provide a brief introduction to VESTEX and a general overview of your member companies?

Karin: VESTEX is the Apparel and Textile Association of Guatemala, a private association representing the Guatemalan textile and apparel export sector. It focuses on promoting the industry’s exports through strategic alliances with public and private institutions at the national and international levels.  Its strategic axes are Sectoral Resilience, which seeks to position the industry as a generator of investment and formal employment in the country; Sectoral Sustainability, through the promotion of sustainability as a long-term strategy for industry continuity and compliance, providing companies in the sector with tools that facilitate compliance with the obligations established in the laws and regulations.

VESTEX partners comprise companies that integrate the entire supply chain of the apparel and textile sector, encompassing yarn and fabric manufacturers, apparel producers, as well as firms providing specialized services and accessories to the industry.

Sheng: Studies show that there is consistent interest among U.S. fashion companies in expanding nearshoring from the Western Hemisphere, including Guatemala. What is your observation? What makes Guatemala an attractive destination for apparel sourcing today? What are the unique advantages of sourcing from the country?

Karin:Guatemala has become an increasingly attractive destination for apparel sourcing due to its unique combination of industrial integration, geographic advantages, and strong compliance standards. The country offers a highly integrated apparel cluster that encompasses every stage of the supply chain—from spinning yarn and weaving fabrics to apparel manufacturing, printing, finishing, and packaging. This full-package model not only streamlines operations and enhances traceability but also allows for greater flexibility and product diversity, raising the added value of garments and positioning Guatemala as a competitive supplier for niche and complex products requiring skilled labor and high-quality materials.

Another key differentiator is Guatemala’s strategic location. With access to ports on both the Atlantic and Pacific coasts—separated by only 249 miles—the country can efficiently serve both the East and West coasts of the United States. Guatemala manages the second-largest maritime cargo operation in Central America (after Panama), which is critical for companies seeking to balance and mitigate geopolitical and logistical risks. In addition, proximity to the U.S. substantially reduces environmental impact: sourcing from Guatemala lowers CO₂ emissions from maritime transport by approximately 84% compared to sourcing from Asia. Transit times are also highly competitive, with shipments reaching Miami in as little as three days, enabling U.S. buyers to manage inventories more effectively and respond to market demands with agility.

Equally important, Guatemalan apparel companies operate under a strong framework of labor and environmental compliance. Companies demonstrate a full-spectrum commitment to input traceability, adherence to strict rules of origin, and continuous process improvement to reduce resource consumption. Investments in monitoring and ESG systems underscore their transparency and alignment with global sustainability standards.

Taken together, this integration of cluster capabilities, geographic proximity, and compliance with international norms positions Guatemala as a reliable, sustainable, and strategically advantageous sourcing partner for U.S. fashion companies.

Sheng: How important is the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR) in supporting Guatemala’s apparel exports to the U.S. market? What impact do CAFTA-DR’s apparel-specific rules of origin have on garment exporters’ supply chains and export strategies in Guatemala?

Karin:CAFTA-DR has provided certainty by encouraging long-term investments in textile infrastructure and capabilities. CAFTA-DR has been the basis for the development of Guatemala’s apparel industry.  The yarn-forward rule established under the agreement has not only fostered integration with the U.S. supply chain but also promoted stronger collaboration among Central American countries. By allowing the accumulation of inputs and processes within the region, CAFTA-DR has significantly strengthened intraregional trade.

This integration has facilitated the specialization of each Central American country. In Guatemala’s case, it has enabled the use of specific yarns and fabrics produced in other countries and manufactured locally, fostering a greater diversification of production.

According to OTEXA figures, in the year ending June 2025, 89.17% of Guatemala’s total apparel exports to the U.S. entered under the Free Trade Agreement preferences. Of this total, 79.69% qualified under the yarn-forward rule—that is, garments made with yarn from the U.S. or yarn produced within one of the Central American countries. CAFTA-DR, and particularly its rules of origin, have been the basis of Guatemala’s strategy in recent years, not only to attract foreign direct investment but also to encourage significant reinvestments.

Sheng: Data shows that an increasing share of yarns and fabrics used by Guatemala garment factories are now locally made in Guatemala and other Central American countries. Could you discuss the recent trends in textile manufacturing capacity building in Guatemala, as well as the industry’s current priorities in building a more vertically integrated regional supply chain?

Karin:Guatemala offers a series of competitive advantages that are reinforcing its role as a regional hub for textile and apparel manufacturing. At the country level, it benefits from a stable macroeconomy, a solid exchange rate, competitive electricity prices within the region, and a reliable energy supply. At the industry level, Guatemala stands out for its robust apparel and textile cluster and highly skilled workforce.

Since the pandemic in 2020, when many global companies accelerated nearshoring strategies, Guatemala has successfully attracted new foreign investment and supported the expansion of companies already established in the country, particularly in the spinning industry. Installed capacity is primarily focused on cotton, although blends are also produced. By the end of 2024, apparel exported to the U.S. consisted of 62.8% cotton, 36.4% synthetics, and 0.8% wool, reflecting the central role of cotton in the country’s production while also showing diversification into other fibers.

Driven by shifting market demand, textile production in Guatemala has been expanding beyond knits, with a modest increase in woven fabrics as well. Investments in innovation and technology have enabled the industry to offer specialized processes, including antimicrobial treatments, absorption, UPF protection, enzymatic washing, softening, and plush finishing, among others. A particularly important advancement has been the investment in elastic knit fabrics, which has opened the door to the production of categories such as sportswear, intimate apparel (seamless), shapewear (technical lingerie and compression fabrics), and medical textiles.

We recognize, however, that there remain challenges and opportunities to broaden the regional textile offering—particularly in the production of yarns and fabrics made from fibers not yet manufactured locally. Expanding capacity in these areas would further strengthen vertical integration and supply chain resilience.

In this context, VESTEX has taken a leading role in supporting and guiding companies interested in exploring these opportunities. In coordination with Guatemala’s foreign direct investment promotion agency, efforts are underway to identify high-demand inputs that are currently unavailable in the region but represent strategic opportunities for local production.

Sheng: Since April 2025, U.S. apparel imports from CAFTA-DR countries, including Guatemala, are subject to a new 10% “reciprocal tariff.” How has this tariff increase and the Trump administration’s trade policy so far impacted Guatemala’s garment industry and exports? 

Karin:The main challenge for Guatemala’s apparel industry under the current U.S. trade policy has been the high degree of uncertainty. Markets and buyers demand stability, yet in recent months orders have slowed significantly as companies await clarity on the tariffs that will ultimately apply to each country. This hesitation has already resulted in lost opportunities: seasonal orders cannot be recovered once the selling window has passed.

Traditionally, Guatemala’s apparel sector grows between 3% and 5% annually; however, 2025 projections have been revised downward, and current expectations suggest growth closer to 1–2%. According to the Central Bank of Guatemala, as of June 2025, exports registered a modest 1.36% increase—well below what was anticipated under normal conditions.

Another major impact has been the need for companies to absorb additional costs to maintain contracts with international brands. This has reduced profit margins, limited reinvestment capacity, and increased pressure on already tight production cycles. Buyers face uncertainty as well: they do not know how much a garment ordered today will cost by the time it is delivered six to nine months later, since tariff rates are subject to abrupt changes. The volatility recalls past episodes in China, where tariffs under former President Trump rose as high as 145% before being reduced to 30%, creating unpredictable supply conditions.

That said, Guatemala continues to hold a relative tariff advantage compared with Asian competitors, where rates now reach 15%, 18%, 25%, or even higher. This gap may ultimately favor Guatemala if U.S. buyers reconfigure sourcing strategies to prioritize suppliers who are both geographically closer and more reliable. Indeed, global sourcing is shifting away from a purely low-cost model toward one that values resilience, speed to market, and compliance.

Sheng: The 2025 US Fashion Industry Association Benchmarking Study indicates that U.S. fashion companies are increasingly seeking sourcing destinations that can provide sustainable apparel products, including those made with preferred fibers such as organic, recycled, regenerative, and biodegradable materials. What strategies or recent initiatives has the Guatemalan textile and apparel industry undertaken to meet this demand for sustainability?

Karin: Guatemalan mills already source recycled polyester yarns, organic or regenerative cotton, and biodegradable materials. Brands are actively demanding these products. In fact, mills have obtained various certifications and adhere to practices focused on circular economy, science-based target initiatives, and other sustainability standards.

Traceability is key for the textile and apparel industry, and Guatemala has managed to implement measures such as data management and continuous improvement as a way to demonstrate this.

  • Adoption of Sustainable Certifications and Standards: Guatemalan manufacturers are obtaining certifications like GOTS (Global Organic Textile Standard), OEKO-TEX, Global Recycled Standard, Recycled Claim Standard, Blue Sign, Higg FEM, among others, ensuring their products meet international sustainability standards.
  • Investment in Technologies: Many mills are upgrading to water and energy-efficient machinery, as well as more sustainable dyeing and finishing processes.
  • Training and Capacity Building: Initiatives to train and certify workers and management on sustainable practices and standards are increasing, promoting a culture of sustainability throughout the industry.
  • Integration of Circular Economy Principles: Some mills are exploring design for recyclability techniques to align with circular economy goals.

These initiatives collectively position the Guatemalan textile and apparel sector as a viable sourcing destination for sustainable fashion, aligning with global market trends and buyer preferences for more sustainable products.

Sheng: In addition to the questions discussed earlier, what are the top business and policy issues facing Guatemala’s textile and apparel industry over the next 1–2 years?

Karin:Over the next 1–2 years, Guatemala’s textile and apparel industry will face several pressing business and policy issues that will shape its competitiveness.

1. Infrastructure and logistics.
A key issue remains the need to strengthen national infrastructure, particularly ports, customs processes, and internal transport routes.

2. Limited availability of regional inputs.
The industry continues to face constraints in the local production of certain yarns, fabrics, and specialized fibers. Inputs such as viscose, spandex, and rayon are not yet manufactured in the region at scale, which limits vertical integration and forces reliance on imports from outside the hemisphere. Expanding textile capacity in these areas is a central issue to ensure resilience and broaden the exportable supply.

3. Market visibility and buyer perception.
Despite its high level of integration, many international buyers remain unaware of Guatemala’s strengths in complex products, compliance, and sustainability. A persistent challenge is to raise global awareness of the country’s capabilities in order to capture greater sourcing opportunities.

4. Policy uncertainty and trade volatility.
The recent 10% reciprocal tariff applied to CAFTA-DR countries has introduced significant uncertainty. Buyers hesitate to place long-term orders when tariff levels are unclear, and this volatility affects sourcing decisions. Stability and predictability in trade policy remain critical issues for the sector.

5. Differentiation and specialization under nearshoring.
Another key challenge is sustaining competitiveness through higher-value products. Today, 54.11% of Guatemala’s apparel exports already include advanced finishing processes, and the industry is investing in spinning, woven fabrics, and technical textiles. However, scaling these capabilities requires reinvestment and foreign capital inflows—both of which are being constrained by global uncertainty. Given that Guatemala currently supplies only about 2% of U.S. apparel imports, a major issue ahead is how to convert this untapped potential into tangible growth.

In short, while the country is positioning itself strategically with competitive tariffs, geographic proximity, and an increasingly sophisticated textile base, the top issues over the next two years will be overcoming infrastructure and logistics bottlenecks, reducing dependence on imported inputs, strengthening promotion to buyers, and navigating trade policy volatility. Addressing these challenges will be crucial for Guatemala to capitalize on long-term opportunities in the ongoing global supply chain reconfiguration.

-The End-

FASH455 Video Discussion: Inside the Costs and Challenges of Making Textiles and Apparel in the U.S.

Video 1: How an Oklahoma denim-maker supports creating American-made jeans
Video 2: President Trump’s Tariffs Backfire on US Textile Exporters

Discussion questions (note: for students in FASH455, please respond to at least two questions listed below in your comment)

  1. Based on the videos, what is your evaluation of the opportunities and challenges of making textiles and apparel in the U.S.?
  2. In what ways has international trade influenced the growth, decline, or transformation of U.S. textile and apparel production?
  3. What do you think about the Round House Jeans owner’s strategy of selling imported jeans from Bangladesh at a higher profit margin to “subsidize” its low-margin U.S.-made jeans? Do you think this could be a sustainable business model in the long run?
  4. Based on the videos, why do you think U.S. textile and apparel production experienced even greater losses in the first half of 2025, despite higher tariffs on imports? [Detailed data HERE]
  5. If you were invited to offer policy recommendations to boost U.S. domestic textile and apparel manufacturing, what would you propose, and why?

Additional reading:

2025 USFIA Fashion Industry Benchmarking Study Released

The full report is HERE.

Key findings of this year’s report:

#1 This year, the top business challenges facing U.S. fashion companies center on the Trump Administration’s escalating tariff policy and its wide-ranging impacts on companies’ sourcing and business operations.

  • 100 percent of respondents rated “Protectionist U.S. trade policies and related policy uncertainty, including the impact of the Trump tariffs” as one of their top business challenges in 2025. This included as much as 95 percent of respondents who ranked the issue among their top two concerns.
  • Respondents also expressed significant concerns about the wide-ranging effects of Trump’s tariff policy, including “Inflation and economic outlook in the U.S. economy” (80 percent), “Increasing production or sourcing cost” (nearly 50 percent), and “Protectionist trade policies and policy uncertainty in foreign countries, including retaliatory measures against the U.S.” (52 percent).
  • Over 70 percent of surveyed companies reported that the higher tariffs increased sourcing costs, squeezed profit margins, and led to higher consumer prices. Approximately half of the respondents reported a decline in sales, and 22 percent stated that they had to lay off employees due to increased tariffs.

#2 Maintaining a geographically diverse sourcing base has been one of the most popular strategies adopted by U.S. fashion companies to mitigate the impact of rising tariffs and policy uncertainty. 

  • This year, respondents reported sourcing apparel products from 46 countries, similar to the 48 countries reported in 2024 and an increase from 44 countries in 2023. At the firm level, approximately 60 percent of large companies with 1,000+ employees reported sourcing from ten or more countries in 2025, a notable increase from the 45–55 percent range reported in 2022 and 2023 surveys.
    • Amid escalating tariffs and rising policy uncertainty, Asia has become an ever more dominant apparel sourcing base for U.S. fashion companies in 2025. Respondents reported increased use of several Asia-based sourcing destinations other than China in 2025 compared to the previous year, including Vietnam (up from 90 percent to 100 percent), Cambodia (up from 75 percent to 94 percent), Bangladesh (up from 86 percent to 88 percent), Indonesia (up from 75 percent to 77 percent), and Sri Lanka (up from 39 percent to 53 percent).As part of their sourcing diversification strategy, U.S. fashion companies are also gradually increasing sourcing from emerging destinations in the Western Hemisphere and beyond, such as Jordan, Peru, and Colombia.
    • Most respondents intend to build a more geographically diverse sourcing base and broaden their vendor network over the next two years. Nearly 60 percent of respondents plan to source apparel from more countries, and another 40 percent plan to source from more suppliers or vendors. Reducing sourcing risk, especially to minimize the impact of rising tariffs and tariff uncertainty, is a key driver of companies’ sourcing diversification strategies

#3 U.S. fashion companies remain deeply concerned about the future of the U.S.-China relationship during Trump’s second term and intend to further “reduce China exposure” to mitigate sourcing risks.

  • While 100 percent of respondents reported sourcing from China this year, a record-high 60 percent of respondents reported sourcing fewer than 10% of their apparel products from China, up from 40 percent in 2024. Approximately 70 percent of respondents no longer used China as their top apparel supplier in 2025, representing a further increase from 60 percent in 2024 and significantly higher than the 25-30 percent range prior to the pandemic.
  • Despite the announcement of the reaching of a U.S.-China “trade deal” in May 2025, more than 80 percent of respondents plan to further reduce their apparel sourcing from China over the next two years through 2027, hitting a new record high. Many large-scale U.S. fashion companies are already limiting or plan to limit their apparel sourcing from China to a “low single-digit” percentage by 2026 or earlier, mainly due to concerns about the increasing geopolitical and trade policy risks associated with sourcing from the country.
  • Still, respondents rated China as highly economically competitive as an apparel sourcing base compared to many of its Asian competitors regarding vertical manufacturing capability, low minimum order quantity (MOQ) requirements, flexibility and agility, sourcing costs, and speed to market. However, non-economic factors, particularly the perceived extremely high risks of facing U.S. import restrictions, geopolitical tensions with the U.S., and concerns about forced labor, are driving U.S. fashion companies to continue their de-risking efforts.

#4 No evidence indicates that the Trump Administration’s tariff policy has successfully encouraged U.S. fashion companies to increase domestic sourcing of “Made in the USA” textile and apparel products or to expand sourcing from the Western Hemisphere.

  • Only about 44 percent of respondents explicitly say that they would expand sourcing from the Western Hemisphere, and even fewer respondents (17 percent) plan to source more textiles and apparel “Made in the USA” amid the tariff increase.
  • This year, fewer respondents reported sourcing apparel from Mexico and Canada (down from 60 percent in 2024 to 50 percent in 2025) and members of the Dominican Republic-Central America Free Trade Agreement, CAFTA-DR (down from 75 percent in 2024 to 64 percent in 2025).
  • About half of the respondents plan to expand apparel sourcing from Mexico and CAFTA-DR members over the next two years. Notably, nearly all of these companies also intend to increase sourcing from Asia, indicating that U.S. fashion companies view near-shoring from the Western Hemisphere as a complement, not a replacement, to their broader sourcing diversification strategy.
  • Respondents consider the most urgent capacity-building needs within CAFTA-DR lie in the production of textile raw materials (e.g., spandex) and accessories (e.g., zippers, threads, and buttons). Meanwhile, USMCA members are considered to have relatively stronger capacities in yarn and fabric production but face more pressing shortages in accessories.

#5 Respondents overall remain highly committed to sustainability, social responsibility, and compliance issues in the sourcing process.

  • This year, the top sustainability and compliance areas where respondents plan to allocate more resources include “Investing in technology to enhance supply chain traceability or isotopic testing” (53 percent), “Providing sustainability and social compliance training for internal employees” (50 percent) and “Providing sustainability and social compliance training for suppliers” (50 percent). 
  • As part of U.S. fashion companies’ sustainability efforts, all respondents (100 percent) report sourcing clothing made with “sustainable textile fibers” in 2025. Having 11–50% of apparel products containing various “sustainable textile fibers” is the most common (40 percent of respondents), followed by having 1–10% of the total sourcing value or volume(30 percent of respondents).
  • Moreover, most respondents (over 70 percent) plan to increase their use of various “sustainable fibers” in clothing over the next three years. This trend is especially strong for recycled materials, with 80 percent of respondents indicating they intend to increase their use.
  • The top three positions with the highest demand among respondents from 2025 through 2030 are “Environmental sustainability-related specialists or managers,” “Trade compliance specialists,” and “Data scientists”—more than 40 percent of respondents plan to increase hiring. There is also strong demand for “Textile raw material specialists” and “Sourcing specialists.”

#6 With the upcoming expiration of the trade preference program this September, respondents again underscore the importance of immediate renewal of the African Growth and Opportunity Act (AGOA) and extending the agreement for at least another ten years.

  • Due to the upcoming expiration of AGOA and uncertainty about its future, this year, respondents sourced from only six SSA and AGOA members (i.e., Kenya, Ethiopia, Ghana, Madagascar, Mauritius, and Tanzania), fewer than the seven countries in 2024.  And none of these countries were used by more than 20 percent of respondents.
  • Nearly 80 percent of respondents support “renewing AGOA for at least another ten years,” and no one opposes. This shows a consistent and wide base of support for AGOA among U.S. fashion companies.
  • More than 70 percent of respondents say that securing a long-term renewal of AGOA for at least ten years is essential for expanding apparel sourcing from the region. Similarly, another 60 percent of respondents believe that a long-term renewal of AGOA is necessary for U.S. fashion companies and their supply chain partners to commit to new investments in the region. 
  • Respondents warned that AGOA’s pending renewal has already begun to harm the region’s prospects as an apparel sourcing base. Approximately 30 percent of respondents explicitly stated that they had already reduced sourcing from AGOA members due to the uncertainty surrounding the agreement’s renewal.

About the study

Authored by Dr. Sheng Lu in collaboration with the United States Fashion Industry Association (USFIA), this year’s benchmarking study was based on a survey of executives from 25 leading U.S. fashion companies from April to June 2025. The study incorporated a balanced mix of respondents representing various businesses in the U.S. fashion industry. Approximately 85 percent of respondents were self-identified retailers, 60 percent were self-identified brands, and about 50 percent were importers/wholesalers.

The survey respondents included large U.S. fashion corporations and medium-sized companies. Around 90 percent of respondents reported having over 1,000 employees; the rest (10 percent) represented medium-sized companies with 100-999 employees.

Average Tariff Rates for U.S. Apparel Imports under Trump’s “Reciprocal Tariff” Policy (Updated July 2025)

The latest data from the U.S. International Trade Commission (USITC) indicates that Trump’s “Reciprocal Tariff” has led to higher import duties on U.S. apparel imports, although the impact on sourcing appears to be more nuanced than expected. Specifically:

As a result of the reciprocal tariff, the average tariff rate for U.S. apparel imports (HS Chapters 61 and 62) reached 23.8% in May 2025, increased further from 20.8% in April 2025 and much higher than 13.9% in May 2024 and 14.7% in January 2025, prior to Trump’s second term. This tariff rate also hit its highest level in decades. Similarly, while the value of U.S. apparel imports in May 2025 decreased by 7% from May 2024, the import duties skyrocketed by nearly 60% over the same period. [View detailed data HERE]

Due to numerous punitive tariffs beginning in February 2025, the average tariff rate for U.S. apparel imports from China reached an unprecedented 69.1% in May 2025, a further increase from 55.0% in April 2025, 37.0% in March 2025 and 22.1% in January 2025. In theory, U.S. apparel imports from China in May should be subject to a tariff rate of over 145%, as mandated by a series of executive orders. However, as “goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 a.m. eastern daylight time on April 5, 2025,“ were excluded from Trump’s reciprocal tariffs, it explains why the actual tariff rate in April and May 2025 appeared lower than the theoretical one.

Nonetheless, affected by the high tariffs, the value of US apparel imports from China in May 2025 was cut by more than half from a year ago (down 52%). China’s market share in US apparel imports in May 2025 also dropped to 9.9%, a new low in decades (note: was 19.9% in May 2024). [View detailed data HERE]

Additionally, the average tariff rate for U.S. apparel imports from countries other than China reached 18.9% in May 2025, up from 15.2% in April 2025. Although this rate was higher than approximately 12-13% before Trump’s second term in early 2025, the increase was still much more modest than the theoretical 10% universal reciprocal tariff rate announced by the Trump administration. The average tariff rates for U.S. apparel imports from leading Asian suppliers such as Vietnam, Bangladesh, and Cambodia followed similar patterns (i.e., higher tariff rates but well below a 10% increase). Similar to China’s case, it appears that U.S. apparel imports from other countries in April 2025 included a significant proportion of products that were exempt from reciprocal tariffs because they were “loaded onto a vessel” early enough. [View detailed data HERE]

It is interesting to note that the reciprocal tariff resulted in the most significant increase in tariff rates on U.S. apparel imports from CAFTA-DR members. While imports from these countries were supposed to be duty-free under the trade agreement, the average tariff rate reached 10% in May 2025, up from 6.7% in April 2025. In other words, the short shipping distance unintentionally “disadvantaged” near-shoring imports from being exempted from the reciprocal tariffs, as they could be mostly loaded after the deadline.

Overall, it remains uncertain how the U.S. apparel tariff rates will continue to evolve in response to Trump’s shifting tariff policy. It appears that the trade volume and timing of shipment will be highly sensitive to short-term tariff rate changes, whereas adjusting sourcing bases and product structures will be a consideration for U.S. fashion companies in the medium to long term.

By Sheng Lu

Additional reading: Apparel Tariffs Climbed to Historic Highs in April (Sourcing Journal, June 13, 2025)

Impacts of Trump’s Escalating Tariffs on Apparel Sourcing: U.S. Fashion Companies’ Perspective

Updated study available: Updated Impact of Increasing Tariffs on U.S. Fashion Companies’ Sourcing and Businesses (October 2025)

(Note: The figure above shows how frequently the term “tariff” was mentioned alongside other key issues in the earnings calls. A higher frequency indicates a more significant impact and a closer connection between tariffs and a specific theme.)

This study aims to examine the impacts of the Trump administration’s escalating tariffs on U.S. fashion companies’ apparel sourcing practices. Based on data availability, transcripts of the latest earnings calls from approximately 25 leading publicly traded U.S. fashion companies were collected. These earnings calls, held between mid-May and June 2025, covered company performance in the first quarter of 2025. A thematic analysis of the transcripts was conducted using MAXQDA.

Overall, the results indicate that the Trump administration’s escalating tariffs and policy uncertainties have financially hurt U.S. fashion companies and disrupted their apparel sourcing practices. To mitigate these impacts, most companies plan to further reduce their “China exposure,” maintain a geographically diversified sourcing base, and prioritize flexibility in sourcing and shipping. However, there is no clear evidence that the current policy environment has successfully incentivized U.S. companies to expand apparel sourcing from the Western Hemisphere, let alone commit to new long-term investments. Meanwhile, U.S. fashion companies have adopted a strategic pricing approach by not passing the entire cost increase to consumers through widespread retail price hikes.

A few key findings:

First, far from surprising, many leading U.S. fashion companies expressed concerns that the Trump administration’s escalating tariffs have resulted in higher sourcing costs and cut companies’ profit margins. For example:

  • Company G (specialty store): if current tariffs of 30% on most imports from China and 10% on most imports from other countries remain for the balance of the year, we estimate a gross incremental cost of approximately $250 million to $300 million.
  • Company O (a parent company of several leading apparel brands): We expect that gross margin will contract approximately 200 basis points for the year. This contraction includes $40 million in additional tariff costs.
  • Company V1 (underwear brand): gross tariff impact of approximately $120 million, which assumes 30% China tariffs and 10% non-China, with tariff mitigation of approximately $70 million for a net impact to fiscal year 2025 of approximately $50 million.

Second, with the hiking tariff rate on U.S. apparel imports from China and increasing strategic competition between the two countries, many leading U.S. fashion companies plan to reduce their apparel sourcing from China to a single-digit, if not move out of the country entirely. For example:

  • Company A1 (apparel brand): We’re on track to reduce our sourcing exposure to China to under 10% this year with fall and holiday season down to low single digits.
  • Company A2 (specialty store): For China specifically, we have worked for some time now to relocate the supply resources, and this year’s sourcing volume from China will be in the low single digits.
  • Company L (apparel brand): Less than 8% of our purchase order dollars last fiscal year were utilized on buys of China.
  • Company O (a parent company of several leading apparel brands): By the second half of 2026, we currently plan to be substantially out of China.
  • Company V2 (a parent company of several leading apparel brands): over the past several years we’ve strategically diversified our supply chain and proactively reduced our US finished goods sourced from China to less than 2%.
  • Company K2 (a parent company of several leading apparel brands): China for us is de minimis.

Third, maintaining a geographically diverse sourcing base remains a popular strategy for U.S. fashion companies to mitigate the impacts of increasing tariffs and ongoing policy uncertainties. Companies particularly intend to avoid “putting too many eggs in one basket” and limiting the reliance on any single supplying country. For example:

  • Company K1 (retailer): our talented and experienced global sourcing team has done an incredible job diversifying our countries of production to ensure that we are not overly reliant on any one country. Although tariffs remain a fluid and uncertain situation, the teams continue to work to reduce our exposure to high tariff countries by leveraging our diverse factory network to move production, adjusting orders based on pricing elasticity analysis.
  • Company G (specialty store): Most other countries represent less than 10%, Vietnam and Indonesia represented 27%, and 19% of our sourcing last year, respectively, and our goal is for no country to account for more than 25% by the end of 2026.
  • Company R (apparel brand): While tariffs will primarily impact our gross margins… we have a proven toolkit to manage cost inflation headwinds. This includes first, significant supply chain diversification…No single country accounts for more than 20% of our production volumes, with most countries representing a single-digit percentage.
  • Company U (retailer): The remaining third is strategically diversified across a number of other countries, each representing a low to mid-single-digit percentage. This deliberate diversification creates a well-balanced portfolio, reducing reliance on any single market and enhancing our ability to navigate geopolitical, costs and supply chain complexities from a position of strength.

Notably, while a limited few companies specifically mentioned the possibility of expanding sourcing from the Western Hemisphere amid the current business environment, most did not. For example:

  • Company L (apparel brand): We intentionally drove significant change in our supply chain as we accelerated production in the Western Hemisphere, giving us both speed and additional avenues to mitigate tariffs and provide resiliency.
  • Company G (specialty store): Diversification also means near-shoring as well as domestic investment.

Fourth, U.S. fashion companies have leveraged shipping timing, piled up inventory, and delayed or cancelled existing orders to mitigate the tariff impacts as much as possible. For example:

  • Company C (sportswear): For products that are impacted by the reciprocal tariffs, we are accelerating shipments to the extent possible in order to receive products during the 90-day tariff.
  • Company K1 (retailer): Inventory was up 1.7% compared to last year, driven by inventory strategies implemented to navigate the tariff pressure, including the pull forward of receipts and pack in holding seasonal inventory to be sold in the back half of the year.
  • Company B (off-price retailer): Our reserve inventory was 48% of our total inventory versus 40% of our inventory last year. In dollar terms, our reserve inventory was up 31% compared to last year, reflecting the great deals we were able to make to get ahead of tariffs.
  • Company M (retailer): With the recent announcement of these tariffs, we’ve renegotiated orders with suppliers, and we’ve canceled or delayed orders where the value proposition is just not where it needs to be.

It should be noted, however, that adjusting shipping and inventory could incur additional costs. For example:

  • Company V1 (underwear brand): More than half of the gross margin rate pressure in the quarter was due to a combination of elevated and expected airfreight rates, some tariff-related order adjustments…

Fifth, despite higher sourcing costs and increasing financial pressures, many U.S. fashion companies have avoided widespread price hikes but have implemented selective increases in less price-sensitive apparel categories. For example:

  • Company V1 (underwear brand): [price increase driven by higher tariffs] And so we are going to sort of play in the middle where we see value. So and it won’t be across all categories. As we think about our business, it’s really that strategic case by case, category by category look that we’re taking.
  • Company U (retailer): gently and sparingly raising some prices. Please note that any price increases will be very strategic, protecting opening price points and only targeting areas where we believe we could raise prices without affecting the overall customer experience.
  • Company A2 (specialty store): we are not planning broad-based ticket increases. As we’ve done season after season, our goal is to deliver high-quality product and align inventory and promotions with our customers’ value perception.
  • Company P (a parent company of several leading apparel brands): We will evaluate strategic discounts to mitigate the potential tariff impact. While we are focused on delivering price value for the consumer, we are also ready to take calibrated targeted pricing actions where we have pricing power.

by Sheng Lu

Additional reading: Tariffs Upend Fashion Sourcing and Disrupt Cash Flow Amid Widening Trade Gap (Sourcing Journal, June 27, 2025)

USDA Released 2025 China Cotton Report

The U.S. Department of Agriculture (USDA) recently released its latest annual China cotton report. Below are the key findings most relevant to U.S. apparel sourcing from the country.

First, China’s retaliatory tariffs could severely impact US cotton exports. Faced with geopolitical tensions and rising competition from other suppliers like Brazil, U.S. cotton exports to China fell sharply by 73% in the first seven months of Marketing Year (MY) 24/25 (i.e., August 2024-February 2025), resulting in a decrease in the U.S. market share to 17.1%, down from 29.6% during the same period in MY 23/24. As noted in the report, “Beijing’s imposition of 140 percent tariffs on U.S. cotton will all but stop further imports from the United States.” Meanwhile, China’s overall demand for raw cotton could fall to a five-year low in MY 24/25, due to insufficient domestic demand and limited growth in textile and apparel exports.

Second, Xinjiang still dominated cotton production in China. Despite the Uyghur Forced Labor Prevention Act (UFLPA), Xinjiang accounted for approximately 92.3% of cotton production in China during MY 24/25 (note: was 90.9% in MY 23/24) and enjoyed an 11.4% year-on-year increase in total production. According to the USDA report, cotton production, yarn spinning, and textile manufacturing in Xinjiang received numerous subsidies from the government, such as support provided to farmers and cotton planting incentives.

The USDA report also noted that, in addition to raw cotton, textile production has experienced substantial growth in Xinjiang. For example, by the end of 2024, Xinjiang’s yarn spinning capacity reached 29.1 million spindles with 62,400 looms in operation, both marking the highest growth rates in history. “The spinning capacity is expected to rise further as the Xinjiang government plans to spin 45 to 50 percent of the Xinjiang cotton by 2028,” according to the USDA.

Third, China’s textile and apparel exports are facing growing headwinds. The USDA report predicted that “With ongoing market turbulences and uncertainties, China’s textile and apparel exports are expected to decrease in the remainder of MY 24/25” due to higher tariffs and the de minimis rule changes. While large-scale textile and apparel companies in China have been relocating some production to Southeast Asia, small-scale companies with limited resources may struggle to adapt. Additionally, according to the USDA, citing industry sources, the profit margin on China’s clothing exports to the US might be 10% or even lower and “the established textile manufacturers will face increased costs and administrative burdens for all import values, potentially disrupting their supply chains and reducing profit margins” due to the recent de minimis rule changes.

Further reading: U.S. and Xinjiang Cotton Are Locked in a Trade War of Their Own (Sourcing Journal)

Impacts of Tariffs: Gen Z’s Perspective

In a new Just-Style mini series, students from FASH455 and the FASH department at the University of Delaware shared their valuable Gen Z perspectives on the impact of the recent tariff increases.

Students’ responses reveal that the impacts of the tariff increase on ordinary U.S. consumers are real, direct, and significant. Like other consumer groups, our Gen Z students express deep concern about the adverse effects of tariffs on the U.S. economy, market uncertainties, and the fashion industry’s growth prospects this year. While shopping for clothing, many students have noticed price increases and reduced product availability due to tariff hikes and related disruptions.

On the other hand, as Gen Z consumers, students send a strong message to fashion brands and retailers—sustainability still matters. In fact, in this environment, students have become ever more conscious of sustainability, asking critical questions such as: Do I really need to buy more clothing? Where was the clothing made? Was the clothing produced ethically? In other words, we may see a growing shift toward “slow fashion” among Gen Z consumers, who expect apparel brands and retailers to make even stronger commitments toward sustainability and social responsibility, instead of compromising these values for “cost mitigation.”

Likewise, students expect higher-quality products or items that can last longer to justify the higher price they pay. Regularly shopping for secondhand clothing, driven by its affordability, environmental benefits, and unique styles, could also become increasingly popular. This leaves an interesting question about the future of cheap but low-quality fast fashion and its attractiveness among Gen Z consumers.

The mini series is available through Just-style. Below are selected comments from students:

Gen Z consumers care about tariffs in the news

Rachel Zemel (Fashion Merchandising and Management major): As a Fashion Merchandising and Management major, I’ve definitely been paying closer attention to how tariffs impact what we see on the sales floor. Learning about global sourcing and trade agreements in class has made me more curious about where products are coming from and how political or economic shifts can directly affect the retail industry. I’ve caught myself checking clothing labels more often to see where things are made and understand why certain brands are shifting their production away from countries like China. I think what used to feel like a distant conversation now feels very connected to the way I shop and think about product availability.

Annabelle Gensler (Fashion Merchandising & Management and Fashion Design & Product Innovation double majors): The tariff discussion has been far more impactful on my shopping habits than I would have imagined…I’d like to consider myself a thoughtful consumer in that I rarely make impulse purchases, and I do what I can to avoid feeling any sense of buyer’s remorse. This has become exceptionally true in today’s evolving state of trade policy and manifests itself in a few ways…As a fashion student, I have a good understanding of what constitutes a fair price for fashion and apparel goods. I try to use these strengths of mine by paying close attention to fiber content, care instructions, origin of materials, and manufacturing location. Overall, I’d say the tariff discussion makes me think twice, three times, ten times before making a purchase.

Alexandra Untu (Fashion Merchandising and Management and Philosophy double majors): As a fashion student and fashion lover, I closely follow tariff updates and actively try to educate myself to gain a more objective and informed perspective on the changes introduced by the current administration. Although I started shopping more consciously a while ago, I’m now more intentional than ever with my purchases…I pay attention to where clothes are made and take the time to research their country of origin and production practices. I’ve also been focusing on buying pieces made from high-quality materials, with timeless styles that are versatile enough to be worn in different outfits and settings.

Lola Kulis (Fashion merchandising and management major and 4+1 graduate student): As a Fashion Merchandising student, I’ve been especially invested in the ongoing discussion around tariffs and their impact on retail pricing. From an industry perspective, it’s scary; as someone preparing to enter the field, I feel uncertain about what the future holds. And as a consumer, I feel frustrated. We’re facing the direct impact of global trade decisions influencing the pricing and accessibility of apparel. The worst part is the uncertainty. The constant policy changes and back and forth are only putting more stress on business owners, consumers, the working class, etc.. The media coverage surrounding these trade policies has made me realize how interconnected global sourcing and retail pricing really are. I’ve started paying closer attention to where garments are manufactured and how those origins might impact cost, availability, and even quality. I’ve shifted my perspective, not only as a student but also as a consumer. 

Madison Toth (Fashion Merchandising and Management major): The tariff discussion in the media has definitely increased my interest in where exactly my clothing is being made. As I shop, I have started to check labels on where these apparel items are being manufactured. It is fascinating to me that the most popular and successful U.S retailers are globally sourcing apparel, yet the increase in tariffs is being thrown into policy. Admittedly, I struggle to keep up with the news, but I’m very intrigued by the current tariff discussion. I follow closely because it will affect my job in the future as I enter my career in the fashion industry, but also as a consumer.

Price hikes and reduced product availability due to tariffs concern Gen Z consumers

Rachel Zemel (Fashion Merchandising and Management major): Since April, I’ve definitely noticed price increases…I’ve also noticed a shift in product availability, especially when I shop online. Certain sizes and styles are gone faster than usual and don’t seem to get restocked. In stores, the selection feels limited too. It seems like brands are being more careful with how much they’re producing, maybe to avoid excess inventory or reduce risk. As someone who shops a lot and also studies this industry, it’s interesting to see how these challenges are playing out in real-time. It makes me think differently about what goes into every piece I buy.

Annabelle Gensler (Fashion Merchandising & Management and Fashion Design & Product Innovation double majors): The majority of the shopping I’ve done since April has occurred online, and the biggest difference I’ve noticed since the tariff discourse has started, is the stock of goods available. It’s rare that I stumble upon a product offering that has all sizes and colors in-stock. Now, when I filter my search for a graduation dress in the size and color I prefer, fewer and fewer items populate. In the past, retailers might have been able to bulk order goods to maintain stock domestically, or ship from international locations directly to the consumer; tariffs have halted these practices. Items I’m considering purchasing no longer feel safe in my cart because of how quickly stockouts are occurring. This, paired with an expectation of drastic increases in price, has created an internal sense of urgency when I have items in my cart. I know it’s unlikely that the item will be available at a certain price point, or at all, and so the conscious consumerism I try to practice is really being put to the test.

Alexandra Untu (Fashion Merchandising and Management and Philosophy double majors): Based on my own and my friends’ experience, the changes have been subtle so far, but noticeable. Prices have been going up gradually across all types of products, including clothing, but the availability of products hasn’t yet turned into a cause for concern. While the current situation is not dramatic as of now, there is undoubtedly a change that is happening, and we are expecting more striking changes in the near future that could affect our shopping behavior quite significantly.

Madeline Osbourn (Fashion Merchandising and Management major): The tariff increase has affected merchandise orders for my sorority. The tariffs have made the prices rise on orders that we planned on making. This creates an issue with prepaid and future orders, keeping in mind the members’ willingness to transition and conform to the higher-priced merchandise that is designed.

Lola Kulis (Fashion merchandising and management major and 4+1 graduate student): Because inflation has been on the rise for some time now, it’s hard to differentiate the cause of these price changes. Prices for basics, like denim, cotton tops, and even activewear, are outrageously high. Over the past year, I’ve observed a significant decline in promotional activity. Retailers are offering fewer discounts, and even Black Friday, once known for major deals, felt noticeably underwhelming. Considering the current global trade and policy changes, I only see this worsening. On the availability side, popular sizes and color options tend to sell out much more quickly, leading to a more competitive shopping experience.

Madison Toth (Fashion Merchandising and Management major): To be honest, I have been reluctant to shop with popular fashion retailers because of the current tariff discussions. I have strayed away from shopping online and in-store due to the uncertainty of the economic climate. While apparel prices are increasing, as well as other products, it is vital for me to take all of that into consideration. Tariffs affect more than apparel, and as a college student, some purchases take priority over clothing. Because of this, I am unable to comment on price and product availability since the tariff discussion began. I have simply decided that, for me personally, in the current economic climate, apparel shopping should be placed on the back burner.

Sustainability matters even more

Rachel Zemel (Fashion Merchandising and Management major): Sustainability matters even more to me now. When prices go up, it forces me to think about the long-term value of what I’m buying. I want to spend my money on items that are made with quality materials and with people and the planet in mind. It’s hard to justify spending more on something that was cheaply made or won’t last beyond a few wears. I think price increases actually help push the conversation toward more conscious consumption. Even with a student budget, I try to prioritize brands that are transparent about their production or at least make some effort toward ethical practices. It’s not always possible to buy 100% sustainably, but I try to balance things. thrifting, supporting small designers, and not overconsuming are just a couple of changes that can have a big impact. Sustainability isn’t just about buying the “right” thing, it’s about shifting the way we shop. That mindset doesn’t go away just because prices are rising.

Alexandra Untu (Fashion Merchandising and Management and Philosophy double majors): Sustainability has always been a core value for me, and that won’t change, even if prices rise. Sustainability isn’t just a trend; it goes far beyond money – it’s a life-or-death issue. It’s a moral responsibility we have to future generations, and we shouldn’t treat it lightly or abandon it. Shopping with sustainability in mind isn’t always the easiest or the cheapest route, but it’s the right one. Now, more than ever, we should be doing -or learning to do – the right thing. Every purchase sends a message about the change we want to see. Every purchase is a small step toward a better, more responsible future for us and for our children.

Lola Kulis (Fashion merchandising and management major and 4+1 graduate student): Sustainability matters even more to me in the face of rising prices. As clothing becomes more expensive, we become more hesitant in purchasing. I think more about what I’m investing in, starting with being intentional about supporting brands that are transparent, responsible, and committed to reducing their environmental impact. I’d rather buy less and choose more wisely than spend more on items that contribute to overproduction and waste. I’ve realized more than ever that sustainability is not a trend, it’s our future. As I prepare to enter the fashion industry, it’s important that I practice what I preach and support the long-term goals.

Madison Toth (Fashion Merchandising and Management major): Sustainability is something that I do genuinely care about. When shopping, I tend to lean more towards brands that practice ethical sourcing and are more transparent about where their items come from. From my time as a student, I have learned many of the horrible outcomes of the fashion industry related to sustainability. From seeing videos of workers begging for higher wages, seeing dyes dumped into bodies of water, and looking at the incredibly tall piles of textile waste, it sticks with me both as a student and a consumer…If a price increase meant that apparel manufacturers were getting paid fair wages, I would purchase those items. However, now, due to tariffs, I am more likely to dodge popular retailers. Sustainability is very important to my generation, and I value the efforts that brands have made to become more sustainable. But it raises the question, when is a price so high that sustainability no longer matters? To that, it’s hard to say. I think it depends on the economic status of each consumer. From sustainable companies with higher prices, there are purchases that I just cannot justify paying. I do care about sustainability, but there does come a point where it becomes financially unattainable.

Katie Yasik (Fashion Design and Product Innovation major): Yes, sustainability still matters to me, even with rising prices. It’s not always easy to prioritize, especially on a student budget, but I try to make more conscious choices like buying fewer, longer-lasting pieces or shopping secondhand. I think it’s important to consider the environmental and social impact of fast fashion, and if prices are going up anyway, I’d rather invest in something that aligns with my values.

Isabella DiGiulio (Fashion merchandising and management major and 4+1 graduate student): I think that the tariffs may bring a new wave of interest in sustainability, specifically for donation-based, second-hand clothing stores. These stores will likely be able to maintain their low pricing because they do not need to account for operational expenses in apparel production. Even if there is to be a price increase, their prices may still remain relatively lower and more affordable compared to first-hand clothing brands…Furthermore, sustainable shopping doesn’t solely refer to purchasing second-hand goods or buying from brands with biodegradable fabrics or ethical labor practices. Sustainable shopping can also refer to the abstinence from shopping. With influences such as social media and fast fashion, overconsumption has become an extremely normalized practice through which many people, especially Gen Z, feel compelled to consistently refresh their wardrobes to follow trends and keep up with the ever-changing standards of style and identity.

Explore more:

FASH455 Current Event Discussion: Ongoing Tariff War and Apparel Sourcing and Trade (Updated April 2025)

Video 1: Is U.S. Clothing Manufacturing at Risk? Tariffs and Competition Threaten Jobs (RT≠ Endorsement)
Video 2: Northern Virginia T-shirt brand faces challenges (RT≠ Endorsement)
Video 3: Tariffs could raise wedding dress prices for American brides (RT≠ Endorsement)
Video 4: Bangladeshi garment industry sweating on Trump tariffs (RT≠ Endorsement)
Video 5: Trump’s Tariff Twist: Can Pakistan’s Textiles Fill China’s Shoes? (RT≠ Endorsement)
Video 6: Tariffs: Europe’s textile sector holds its breath

Discussion questions (note: you may answer any of the following questions. However, you must watch all the videos above and use examples from the videos to support your viewpoints and arguments. For this learning activity, students are expected to form their own independent assessments of the topic.)

#1 Based on the videos, how do you expect the apparel sourcing strategy of US fashion companies to evolve in response to the tariff increase? For example, will companies continue to diversify sourcing, wait and see, or focus on expanding sourcing to countries or regions regarded as “safe havens”?

#2 Do you expect the higher tariffs on U.S. imports, including textiles and apparel, to benefit domestic “Made in the USA” production? Why or why not?

#3 As consumers, how do you perceive the impact of the tariffs on your shopping behavior and experiences? Have you noticed any changes, such as in price and product availability, while shopping for clothing recently? Feel free to share your observations.

#4 Are there any other notable impacts of the tariff increase on the global fashion apparel industry that we should be aware of? What additional questions do you have in mind about the tariff impacts?  

Exploring the “Pink Tariff”

Begin at 36 minutes; Students are expected to form their own independent assessments of the topic.

Additional readings:

Discussion questions:

  • What do you think about the pink tariff? How does the pink tariff affect different stakeholders, including consumers and fashion companies?
  • How can fashion companies respond to or navigate pink tariffs in their global sourcing, particularly considering the tariff escalation in 2025?
  • What role can governments and international trade organizations play in addressing pink tariffs, and what policy changes could help eliminate the disparities? What are the challenges?

Textile and Apparel Industry Stakeholders Comment on Trump’s “Reciprocal Tariffs”

Background: Pursuant to the America First Trade Policy Presidential Memorandum and the Presidential Memorandum on Reciprocal Trade and Tariffs, the Office of the U.S. Trade Representative (USTR) solicited public comments on the proposed “Reciprocal Tariffs” from February to March 2025. Below is a summary of comments submitted by stakeholders in the textile and apparel industry.

The United States Fashion Industry Association (USFIA), whose members include many leading U.S. fashion brands and retailers, opposes raising tariffs and argues for lowering tariffs on textile and apparel products where the U.S. imposes a higher tariff rate than its trading partners. According to USFIA, higher tariffs on apparel and textiles would disproportionately impact lower-income U.S. consumers:

  • “A true ‘reciprocal’ trade policy would lower tariffs on the products of trading partners that maintain lower tariffs than the United States.”
  • “We recommend that the most successful policy to achieve trade reciprocity would be for the United States to lower the tariff rates of products for which our trading partners apply lower tariff rates. For consumer products such as textiles and apparel, this would help combat inflation and assist consumers who struggle to afford basic necessities.”​

The American Apparel and Footwear Association (AAFA), representing U.S.-based “apparel, footwear and other sewn products companies”, opposes broad tariffs on apparel, footwear, and textiles. It is of concern to AAFA that the apparel and footwear sector already faces some of the highest tariffs in the U.S., and tariffs are a “hidden, regressive tax that falls harder on lower-income Americans.” Even worse, AAFA worries that higher tariffs would benefit “Illicit traders” and tariff threats would undermine the regional textile and apparel supply chain in the Western Hemisphere:

  • “Illicit traders are better positioned to escape paying proper duties or any duties at all. Higher tariffs end up maximizing the profit and market access they can gain at the expense of legitimate shippers.”
  • “Recent tariff threats particularly on our neighbors, Canada and Mexico, are especially concerning as the U.S.-Mexico-Canada Agreement (USMCA) review is about to begin. Canada is a key export market for U.S. made apparel and footwear while Mexico is a major source of a wide variety of apparel, including denim imports. Not only does the threat of tariffs cast uncertainty but it also undermines future investment and nearshoring opportunities.”

National Council of Textile Organizations (NCTO), representing U.S. textile mills, supports targeted tariffs against “unfair trade” but opposes penalties on Western Hemisphere trading partners:

  • “We strongly recommend that the Trump administration take a targeted approach to raise tariffs on specific countries that disrupt markets through the use of blatantly unfair and often illegal trade practices, while simultaneously operating in home markets that remain mostly closed to our products.”
  • “We must preserve and strengthen existing trade relationships with U.S. free trade agreement (FTA) countries in the Western Hemisphere that offer valuable markets for U.S.-made textiles.”
  • “We strongly believe that reciprocity should not mean a race to the bottom with lower tariffs on imports from other countries into our market. Rather, reciprocity should hold bad actors accountable for systemic unfair trade practices that have hurt domestic manufacturers.”
  • “We urge the Trump administration to take several actions immediately to make textile and apparel trade more reciprocal and to support the domestic industry…Aggressively raise tariffs on imports of textile and apparel products from China and other trade predators in Asia…Close the de minimis loophole for all countries…”

SMART (Secondary Materials and Recycled Textiles Association), representing businesses engaged in the collection, reuse, conversion, and recycling of textiles and other secondary materials, advocates for addressing trade barriers that affect U.S. secondhand clothing exports. SMART also opposes CAFTA-DR members using the “yarn-forward” rules of origin for imports of secondhand clothing (HTS 6309) from the U.S. under the agreement.

National Retail Federation (NRF), generally representing all types of U.S. retailers, opposes broad-based tariffs, arguing that they increase consumer costs, disrupt supply chains, and hurt retailers. NRF supports targeted measures against unfair trade practices but warns against policies that could lead to unnecessary retaliation from U.S. trading partners.

  • “We believe that high, across-the-board tariffs will undermine the economic growth signaled by the other features of the president’s agenda and have lasting negative consequences for consumers and workers. If the goal of reciprocal tariffs is to enter into negotiations to remove barriers to trade, this will unlock economic growth and reduce prices for consumers. However, if the goal is primarily to raise tariffs, then the opposite is true.”
  • “There are plenty of areas where U.S. tariffs are actually much higher than our trading partners, for example, especially when you look at U.S. tariffs on low value apparel and footwear. These regressive tariffs hurt low- and middle-income consumers the most.”
  • “The administration should also consider the potential for retaliation from our trading partners on any reciprocal tariffs that are established. We are already witnessing our trading partners respond to strong tariff actions by the administration. This will further impact our farmers and manufacturers who are looking to gain access to those foreign markets.”
  • “We need to focus on key high-priority sectors where it makes sense to return manufacturing home or areas where there is strategic competition. High tariffs on everyday household goods, which could raise consumer prices, should not be the focus of such a policy.”

Parkdale Mills, a leading producer of spun yarns based in North Carolina, expressed concerns about “unfair trade practices” from its Asian competitors. Parkadel also calls for closing the “De minimis” loophole.

  • “Each week millions of pounds of product move through our free trade agreement partner countries illegally causing significant damage to the domestic textile industry. Non qualifying goods are shipped using false HTS codes, False Certificates of Origin, and illegal inputs to circumvent the required duty for US entry.”
  • “Section 321 De Minimis (imports)…are shipped into the US each day without inspection or any type of customs enforcement causing millions in lost revenue and again, thousands of lost jobs. This loophole must be closed.”

Apparel Import Tariff Rates around the World (updated March 2025)

Apparel products are often subject to high tariffs for various reasons. In developed countries such as the United States, apparel has long been considered an “import-sensitive” sector, with relatively high tariff rates imposed primarily to “protect” specific domestic interest groups with political influences.

However, as importers, not exporters, pay the tariffs, heavy import duties have been a significant concern for US fashion companies for decades. According to data from the US International Trade Commission (USITC), in 2024, apparel (HS chapters 61 and 62) accounted for about 2.5 percent of total US imports but contributed approximately 15.6 percent of total tariff duties. Likewise, US fashion companies paid $11.9 billion in tariffs on apparel imports in 2024, an increase from $11.6 billion in 2023. The average applied tariff rate for apparel items reached 14.6% in 2024, a notable increase from 13.7% before the imposition of Section 301 tariffs on Chinese products. Additionally, due to retail markups, every $1 in tariffs could result in a $1.50 to $2 increase in the final retail price.

Meanwhile, developing countries, especially those least developed, also often impose high tariffs on apparel—either to protect their nascent domestic industries from import competition or to generate government revenues. For example, in Africa, the apparel import tariff rate commonly exceeds 35% as of 2023 (the latest data available).

In February 2025, President Trump announced the imposition of a so-called “reciprocal tariff,” aiming to  “match” the tariff rates that other countries impose on US exports, thereby promoting “fairer trade practices.” However, the details of the “reciprocal tariff” idea remain highly uncertain.

In theory, if strict “tariff matching” is required on a product-by-product basis, US apparel imports from most leading sourcing destinations—particularly those in Asia without a free trade agreement with the US–would face a significant increase in tariffs. Similarly, beneficiary countries under the African Growth and Opportunity Act (AGOA) could face a similar issue, as AGOA is a trade preference program that does not provide duty-free market access for US products in Africa. If apparel exports from AGOA-member countries to the US were subjected to the same 35%+ tariff rates that US products currently face in their markets, it would be a devastating scenario.

By Sheng Lu

(note: this post is not open for comment/discussion)

How Tariffs Affect U.S. Apparel Import Prices and Retail Prices? Evidence from Monthly Trade Data (2015-2024)

According to the “America First Trade Policy” released in January 2025, the Trump administration aims to leverage tariffs to achieve various policy objectives, from reducing the U.S. trade deficit to countering “unfair” trading practices.

On February 1, 2025, the Trump Administration further announced the implementation of a 25% punitive tariff on imports from Canada and Mexico, along with an additional 10% punitive tariff on goods from China, in addition to the existing duties. With over 98% of clothing sold in the U.S. imported from abroad, U.S. fashion apparel companies are likely to be among the hardest hit by the tariff increase, particularly since Mexico and China are two of the leading apparel-sourcing destinations for the country.

This study aims to explore the dynamic relationship between U.S. apparel import tariffs, U.S. apparel import prices, and U.S. apparel retail prices. Since tariff rates, import prices, and retail prices are interrelated, a vector autoregression model (VAR) was used to analyze their interactions. The analysis was based on monthly data from January 2015 to November 2024 (latest data available), including:

  • U.S. apparel tariff rate (data source: USITC; tariff rate=value of calculated duties/custom values)
  • Price index of U.S. apparel imports (data source: St. Lous Federal Reserve; January 2015=100)
  • Price index of U.S. apparel retail price (data source: St. Louis Federal Reserve; January 2015=100)
  • Index of U.S. apparel retail sales (data source: St. Louis Federal Reserve; January 2015=100)
  • Consumer Price Index for all U.S. urban consumers (data source: St. Louis Federal Reserve; January 2015=100)

The results show that:

First, from January 2015 to November 2024, the average U.S. apparel tariff rate ranged from 12% to 17%. The fluctuation of the tariff rate during that period was primarily caused by the U.S. imposition of Section 301 punitive tariffs on imports from China, along with fashion companies shifting their sourcing from China to other countries, including members of U.S. free trade agreements.

Second, the average price of U.S. apparel imports rose by approximately 6% from January 2015 to November 2024, which aligns with the U.S. apparel retail price increase of 4%. However, this increase was significantly lower than the 34% rise in the U.S. Consumer Price Index (CPI) over the same period. This pattern shows that despite overall inflation and higher operational costs, apparel exporters and U.S. retailers remained cautious about increasing prices due to intense market competition.

Third, the impulse response function (IRF) indicates that a positive tariff shock (i.e., a tariff increase) would lead to a rise in the U.S. apparel retail price. However, the magnitude of this effect is moderate, with the impact being most felt two months later. Specifically, a one-standard-deviation increase in tariffs would result in a 0.16 standard deviation increase in retail prices during Period 3. In other words, the price effect of the tariff increase typically appears in about two months. However, U.S. fashion retailers usually do not transfer the entire burden of tariffs to consumers, likely because of fierce competition in the market.  

Fourth, the impulse response function (IRF) indicates that a positive tariff shock (i.e., a tariff increase) would lead to a slight decline in U.S. apparel import prices. This price decrease would also persist for about three months. Specifically, a one-standard-deviation increase in tariffs would result in approximately a 0.01 standard deviation decrease in apparel import prices through Period 4. This result aligns with previous studies indicating that following the implementation of Section 301 punitive tariffs in 2018, some Chinese exporters agreed to reduce their selling prices to keep sourcing orders.

Fifth, the impulse response function (IRF) further shows that a positive tariff shock (i.e., a tariff increase) could hurt U.S. apparel retail sales in the short to medium term. Specifically, a one-standard-deviation increase in tariffs would lead to approximately a 0.82-2.33 standard deviation decrease in U.S. apparel retail sales from Period 3 through Period 5. This result may be driven by higher selling prices, suppressing consumer spending on clothing.  

Additionally, the variance decomposition analysis reveals that, in the short to medium term, about 50% to 80% of the variation in U.S. retail prices is explained by its own past values, underscoring the persistence of retailers’ pricing practices. Meanwhile, U.S. apparel retail sales account for about 27% of the changes in U.S. apparel retail prices. In comparison, apparel tariff changes explained only about 5% of the retail price fluctuations. In other words, market factors, particularly consumer demand, play a more significant role in shaping fashion companies’ pricing decisions than tariffs.

In summary, the study’s findings confirm the interconnections between apparel tariff rates, U.S. apparel import prices, and U.S. retail prices, although these relationships turn out to be more complex and nuanced than previously suggested. It is important to note that only apparel imports from China were subject to tariff increases during the examined period in this study. If tariffs were to increase on apparel products from a broader range of countries during Trump’s second term, the economic impact on U.S. apparel retail prices could be much more significant and persistent.

By Sheng Lu

Outlook 2025–Key Issues to Shape Apparel Sourcing and Trade

In December 2024, Just-Style consulted a panel of industry experts and scholars in its Shape of apparel sourcing in 2025 briefing. Below is my contribution to the report. Welcome any comments and suggestions!

What’s next for apparel sourcing

Although the world economy is predicted to grow at a similar pace in 2025 from 2024, the slowing US and Chinese economies could impose new challenges to apparel sourcing, from weakened demand to intensified price competition.

Regarding the macroeconomic environment in 2025, which “sets the tone” for apparel sourcing, the International Monetary Fund (IMF) and the World Bank estimated that the world economy would grow by approximately 2.7-3.2 percent in 2025, with almost no change from the previous year. Similarly, the World Trade Organization (WTO) projected that world merchandise trade would increase by 3.3 percent in 2025, slightly higher than 2.6 percent in 2024.

Despite this incremental improvement, the world’s two largest economies–the US (with 2.2 percent GDP growth in 2025, down from 2.8 in 2024 and 2.9 in 2023) and China (with 4.5 percent GDP growth in 2025, down from 4.8 in 2024 and 5.2 in 2023) are expected to experience slower economic growth in the new year ahead. This slowdown means that apparel producers around the world, particularly those developing countries making large-volume basic items, will likely continue to struggle with a shortage of souring orders in 2025 due to overall weak import demand.

Even more concerning, as China grapples with declining domestic sales, the world clothing market could see an additional influx of low-cost Chinese products, especially through new e-commerce channels. Notably, less than half of China’s clothing production is exported, indicating its significant untapped export capacity. Furthermore, while China’s wage levels are higher than those in many other Asian apparel-producing countries, the unit price of U.S. apparel imports from China measured in dollar per square meter equivalent ($/SME) dropped by more than 21% between 2018 and 2024 (up to October). In contrast, U.S. apparel import prices from the rest of the world increased by 7.8% over the same period. Related to this, what is often overlooked is that even Shein, the “ultra-fast fashion” retailer known for its exceptionally competitive pricing, deliberately opted out of the vast Chinese market due to concerns about the intense price competition there. In other words, disregarding the new Trump tariff, 2025 could see an escalation of trade tensions targeting Chinese products in the US market and beyond.

Meanwhile, due to concerns about rising geopolitical tensions worldwide and trade policy uncertainty during Trump’s second term, fashion companies will likely continue to leverage sourcing diversification to mitigate risks. However, the “reducing China exposure” and sourcing diversification movement has yet to substantially benefit near-shoring or emerging sourcing destinations such as the Western Hemisphere and Sub-Saharan Africa (SSA). This result was mainly because fashion companies utilized China to source a wide range of various products, whereas Western Hemisphere and SSA suppliers can only produce a few basic categories.

For example, my latest studies show that in the first nine months of 2024, even excluding major platforms like Shein, Amazon, and Temu, US fashion companies sourced more than 60K Stock Keeping Units (SKUs) of clothing items from China. In comparison, India and Vietnam each supplied approximately 15K SKUs, Cambodia and Bangladesh each contributed 3,000 SKUs, Mexico provided only 2K SKUs, and CAFTA-DR and AGOA member countries supplied around 200 SKUs each. Therefore, even if fashion companies report sourcing from more countries, they are likely to stay sourcing from more Asian countries with closer export capacity and structure to China. Meanwhile, the total value or volume of trade may not fully capture the whole picture of sourcing diversification. This trend may persist in 2025, even with new tariff escalations.

Apparel industry challenges and opportunities

Today’s fashion business is highly global and relies heavily on the frequent movement of goods and services across borders. Thus, the uncertain and protectionist nature of U.S. trade policy during Trump’s second term could present significant challenges to the fashion industry in 2025. Of particular concern is that Trump’s new tariff actions would raise fashion companies’ sourcing costs, create additional inflationary pressure, reduce US consumers’ purchasing power on clothing, and trigger retaliatory trade measures from U.S. trading partners, ultimately hurting the U.S. economy. Notably, when the 7.5% Section 301 tariff was imposed on selected Chinese clothing products in 2018, the U.S. Consumer Price Index (CPI) growth was relatively low at 1.9%. However, imposing a 20% global tariff, a 60% tariff on Chinese products, and the existing 15%-30% regular tariff on clothing when the CPI is historically high is like “adding fuel to the fire.”

Besides tariffs, in 2025, if not sooner, U.S. fashion companies and many e-commerce suppliers worldwide will closely watch how Congress and the new Trump administration reform the de minimis rule, which currently exempts small-value shipments under $800 from tariffs and most customs procedures.  With Trump’s new tariffs looming, some argue that closing the de minimis “loophole” has become even more urgent, as it creates more financial incentives to use the rule to bypass the tariff increase. Meanwhile, proposals under consideration suggest removing textile and apparel products entirely from de minimis, a move that could be an “earthquake” for those fashion companies utilizing the rule heavily.

Trump’s approach and philosophy toward conventional trade agreements and trade preference programs in 2025 also deserve attention. During his first term, Trump launched a few bilateral trade negotiations, from the one with the United Kingdom and Japan to Kenya. Back then, Trump saw a bilateral agreement would give the U.S. more leverage for a better “deal.” Specifically related to apparel sourcing and trade, two flagship U.S. trade preference programs–the African Growth and Opportunity Act (AGOA) and the Haiti HOPE/HELP Act, will expire in September 2025. It remains uncertain whether the new Trump administration will support the early renewal of these two trade preference programs with minimal changes or prefer to renegotiate them and add new bilateral elements.

Additionally, even though the new Trump administration may not prioritize addressing climate change, it is an irreversible trend for fashion companies to allocate more resources to comply with upcoming or newly implemented sustainability and environmental-related legislation, whether from the EU or the US state level. Unlike in the past, when being more sustainable only meant adding operational costs or paying a “one-time fee,” today’s new generation of sustainability-focused regulations—such as Extended Producer Responsibility (EPR)—requires companies to shift their mindset and demonstrate continuous improvement. Interestingly, my recent study tracking apparel products’ sustainability claims shows that vague terms like “sustainable” and “eco-friendly” are gradually being replaced by more neutral, fact-based keywords such as “regenerative,” “textile waste,” and “low impact.”

Meanwhile, offering “sustainable” apparel products and those using “preferred sustainable fibers” could provide fashion companies new opportunities to diversify their sourcing base and expand their vendor networks. For example, studies show that in the U.S. market, China and many other Asian countries are not necessarily the top suppliers of clothing made with recycled materials. Instead, Europe and countries in the Western Hemisphere or even Africa present unique sourcing advantages and capacities due to the unique nature of such products. Therefore, in 2025, we can expect an ever-closer collaboration between design, product development, merchandising, sourcing, and legal teams within fashion companies, working together to meet the growing demand for sustainable apparel and ensure compliance with evolving regulations.

by Sheng Lu

FASH455 Learning Activity: Exploring US Import Tariffs

Part I: Watch the following two videos on tariffs—one from an economic perspective and the other from a political perspective.

Part II: Check the respective tariff rate for the following products by copying and pasting the HS code into the search box

  • Product 1 (men’s and boys’ overcoat, cotton): HS code 6101.20.00
  • Product 2 (cotton): HS code 5201.00.05
  • Product 3 (smartphone): HS code 8517.13.00

Discussion question: Based on the videos and your findings, how would you explain the differences in tariff rates for these products? Do you think tariffs are still necessary in the 21st century?

Additional readings (RT≠ endorsement):

FASH455 Video discussion: What global trade deals are really about?

Instructions: In the next few weeks of FASH455, we will learn about many technical aspects of free trade agreements related to apparel sourcing and trade, such as the preferential tariff rates, apparel-specific rules of origin, and trade agreement utilization. However, this presentation takes a different perspective on trade deals– why they are NOT solely about job creation, why trade agreements increasingly focus on “measures behind borders,” and why international institutions like the World Trade Organization (WTO) were established.

Feel free to share your thoughts on the video. You may focus on 1-2 specific points that you find interesting, intriguing, controversial, or debatable and then explain your arguments. You could also propose additional discussion questions for your classmates.

Terminologies mentioned in the video and background notes:

  • Quota: A quantity restriction on imports. Before 2005, the global textile and apparel trade was subject to 30 years+ quota restrictions. See here for the background information.
  • Tariff: A tax levied on imports only. Deemed as “import-sensitive,” US still imposes a much higher tariff rate for textile (8.0%) and apparel products (11.6%) than other manufactured goods (2.2%) on average in 2023. See the World Tariff Profile 2023.
  • Non-tariff barriers (NTB): refers to trade barriers other than tariffs, such as technical barriers of trade (TBT), Sanitary and Phytosanitary (SPS) measures, customs procedures, import licensing, and many others. See more examples here.
  • GATT and WTO: The General Agreement on Tariffs and Trade (GATT) was a temporary international treaty signed in 1947 by 23 countries (including the United States). GATT aimed to boost trade-led economic recovery after World War II. Since then, GATT members conducted nine major rounds of negotiations to gradually reduce trade barriers, ultimately establishing the World Trade Organization (WTO) in 1995 as the permanent body governing world trade.
  • Trans-Pacific Partnership (TPP): A trade agreement reached by eleven countries in the Asia-Pacific region (Australia, Brunei, Canada, Chile, Japan, Malaysia, Mexico, New Zealand, Peru, Singapore, and Vietnam) and the United States in 2016. However, the Trump Administration announced the withdrawal of the United States from TPP in January 2017. Afterward, without the US, the other 11 TPP members reached the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), which officially entered into force in December 2018.

US-China Tariff War and Apparel Sourcing: A Four-Year Review (updated December 2022)

On September 2, 2022, the Office of the US Trade Representative (USTR) announced it would continue the billions of dollars of Section 301 punitive tariffs against Chinese products. USTR said it made the decision based on requests from domestic businesses benefiting from the tariff action. As a legal requirement, USTR will launch a full review of Section 301 tariff action in the coming months.

In her remarks at the Carnegie Endowment for International Peace on Sep 7, 2022, US Trade Representative Katharine Tai further said that the Section 301 punitive tariffs on Chinese imports “will not come down until Beijing adopts more market-oriented trade and economic principles.” In other words, the US-China tariff war, which broke out four years ago, is not ending anytime soon.

A Brief History of the US Section 301 tariff action against China

The US-China tariff war broke out as both unexpected and not too surprising. For decades, the US government had been criticizing China for its unfair trade practices, such as providing controversial subsidies to state-owned enterprises (SMEs), insufficient protection of intellectual property rights, and forcing foreign companies to transfer critical technologies to their Chinese competitors. The US side had also tried various ways to address the problems, from holding bilateral trade negotiations with China and imposing import restrictions on specific Chinese goods to suing China at the World Trade Organization (WTO). However, despite these efforts, most US concerns about China’s “unfair” trade practices remain unsolved.

When former US President Donald Trump took office, he was particularly upset about the massive and growing US trade deficits with China, which hit a record high of $383 billion in 2017. In alignment with the mercantilism view on trade, President Trump believed that the vast trade deficit with China hurt the US economy and undermined his political base, particularly with the working class.

On August 14, 2017, President Trump directed the Office of the US Trade Representative (USTR) to probe into China’s trade practices and see if they warranted retaliatory actions under the US trade law. While the investigation was ongoing, the Trump administration also held several trade negotiations with China, pushing the Chinese side to purchase more US goods and reduce the bilateral trade imbalances. However, the talks resulted in little progress.

President Trump lost his patience with China in the summer of 2018. In the following months, citing the USTR Section 301 investigation findings, the Trump administration announced imposing a series of punitive tariffs on nearly half of US imports from China, or approximately $250 billion in total. As a result, for more than 1,000 types of products, US companies importing them from China would have to pay the regular import duties plus a 10%-25% additional import tax. However, the Trump administration’s trade team purposefully excluded consumer products such as clothing and shoes from the tariff actions. The last thing President Trump wanted was US consumers, especially his political base, complaining about the rising price tag when shopping for necessities. The timing was also a sensitive factor—the 2018 congressional mid-term election was only a few months away.

President Trump hoped his unprecedented large-scale punitive tariffs would change China’s behaviors on trade. It partially worked. As the trade frictions threatened economic growth, the Chinese government returned to the negotiation table. Specifically, the US side wanted China to purchase more US goods, reduce the bilateral trade imbalances and alter its “unfair” trade practices. In contrast, the Chinese asked the US to hold the Section 301 tariff action immediately.

However, the trade talks didn’t progress as fast as Trump had hoped. Even worse, having to please domestic forces that demanded a more assertive stance toward the US, the Chinese government decided to impose retaliatory tariffs against approximately $250 billion US products. President Trump felt he had to do something in response to China’s new action. In August 2019, he suddenly announced imposing Section 301 tariffs on a new batch of Chinese products, totaling nearly $300 billion. As almost everything from China was targeted, apparel products were no longer immune to the tariff war. With the new tariff announcement coming at short notice, US fashion brands and retailers were unprepared for the abrupt escalation since they typically placed their sourcing orders 3-6 months before the selling season.

Nevertheless, Trump’s new Section 301 actions somehow accelerated the trade negotiation. The two sides finally reached a so-called “phase one” trade agreement in about two months. As part of the deal, China agreed to increase its purchase of US goods and services by at least $200 billion over two years, or almost double the 2017 baseline levels. Also, China promised to address US concerns about intellectual property rights protection, illegal subsidies, and forced technology transfers. Meanwhile, the US side somewhat agreed to trim the Section 301 tariff action but rejected removing them. For example, the punitive Section 301 tariffs on apparel products were cut from 15% to 7.5% since implementing the “phase one” trade deal.

Trump lost the 2020 presidential election, and Joe Biden was sworn in as the new US president on January 20, 2021. However, the Section 301 tariff actions and the US-China “phase one” trade deal stayed in force. 

Debate on the impact of the US-China tariff war

Like many other trade policies, the US Section 301 tariff actions against China raised heated debate among stakeholders with competing interests. This was the case even among different US textile and apparel industry segments.

On the one hand, US fashion brands and retailers strongly oppose the punitive tariffs against Chinese products for several reasons:

First, despite the Section 301 tariff action, China remained a critical apparel sourcing base for many US fashion companies with no practical alternative. Trade statistics show that four years into the tariff war, China still accounted for nearly 40 percent of US apparel imports in quantity and about one-third in value as of 2021. According to the latest data, in the first ten months of 2022, China remained the top apparel supplier, accounting for 35% of US apparel imports in quantity and 22.2% in value. Studies also consistently find that US fashion companies rely on China to fulfill orders requiring a small minimum order quantity, flexibility, and a great variety of product assortment.

Second, having to import from China, fashion companies argued that the Section 301 punitive tariffs increased their sourcing costs and cut profit margins. For example, for a clothing item with an original wholesale price of around $7, imposing a 7.5% Section 301 punitive tariff would increase the sourcing cost by about 5.8%. Should fashion companies not pass the cost increase to consumers, their retail gross margin would be cut by 1.5 percentage points. Notably, according to the US Fashion Industry Association’s 2021 benchmarking survey, nearly 90 percent of respondents explicitly say the tariff war directly increased their company’s sourcing costs. Another 74 percent say the tariff war hurt their company’s financials.

Third, as companies began to move their sourcing orders from China to other Asian countries like Vietnam, Bangladesh, and Cambodia to avoid paying punitive tariffs, these countries’ production costs all went up because of the limited production capacity. In other words, sourcing from everywhere became more expensive because of the Section 301 action against China. 

Further, it is important to recognize that fashion companies supported the US government’s efforts to address China’s “unfair” trade practices, such as subsidies, intellectual property rights violations, and forced technology transfers. Many US fashion companies were the victims of such practices. However, fashion companies did not think the punitive tariff was the right tool to address these problems effectively. Instead, fashion brands and retailers were concerned that the tariff war unnecessarily created an uncertain and volatile market environment harmful to their business operations.

On the other hand, the National Council of Textile Organizations (NCTO), representing manufacturers of fibers, yarns, and fabrics in the United States, strongly supported the Section 301 tariff actions against Chinese products. As most US apparel production had moved overseas, exporting to the Western Hemisphere became critical to the survival of the US textile industry. Thus, for years, NCTO pushed US policymakers to support the so-called Western Hemisphere textile and apparel supply chain, i.e., Mexico and Central American countries import textiles from the US and then export the finished garments for consumption. Similarly, NCTO argued that Section 301 tariff action would make apparel “Made in China” less price competitive, resulting in more near sourcing from the Western Hemisphere.

However, interestingly enough, while supporting the Section 301 action against finished garments “Made in China,” NCTO asked the US government NOT to impose punitive tariffs on Chinese intermediaries. As NCTO’s president testified at a public hearing about the Section 301 tariff action in 2019,

“While NCTO members support the inclusion of finished products in Section 301, we are seriously concerned that…adding tariffs on imports of manufacturing inputs that are not made in the US such as certain chemicals, dyes, machinery, and rayon staple fiber in effect raises the cost for American companies and makes them less competitive with China.”

Mitigate the impact of the tariff war: Fashion Companies’ Strategies

Almost four years into the trade war, US fashion companies attempted to mitigate the negative impacts of the Section 301 tariff action. Notably, US apparel retailers were cautious about raising the retail price because of the intense market competition. Instead, most US fashion companies chose to absorb or control the rising sourcing cost; however, no strategy alone has proven remarkably successful and sufficient.

The first approach was to switch to China’s alternatives. Trade statistics suggest that Asian countries such as Vietnam and Bangladesh picked up most of China’s lost market shares in the US apparel import market. For example, in 2022 (Jan-Nov), Asian countries excluding China accounted for 51.2% of US apparel imports, a substantial increase from 41.2% in 2018 before the tariff war. In comparison, about 16.4% of U.S. apparel imports came from the Western Hemisphere in 2021 (Jan-Nov), lower than 17.0% in 2018. In other words, no evidence shows that Section 301 tariffs have expanded U.S. apparel sourcing from the Western Hemisphere.

The second approach was to adjust what to source from China by leveraging the country’s production capacity and flexibility. For example, market data from industry sources showed that since the Section 301 tariff action, US fashion companies had imported more “Made in China” apparel in the luxury and premium segments and less for the value and mass markets. Such a practice made sense as consumers shopping for premium-priced apparel items typically were less price-sensitive, allowing fashion companies to raise the selling price more easily to mitigate the increasing sourcing costs. Studies also found that US companies sourced fewer lower value-added basic fashion items (such as tops and underwear), but more sophisticated and higher value-added apparel categories (such as dresses and outerwear) from China since the tariff war.

China is no longer treated as a sourcing base for low-end cheap product
More apparel sourced from China target the premium and luxuary market segments

Related, US fashion companies such as Columbia Sportswear leveraged the so-called “tariff engineering” in response to the tariff war. Tariff engineering refers to designing clothing to be classified at a lower tariff rate. For example, “women’s or girls’ blouses, shirts, and shirt-blouses of man-made fibers” imported from China can tax as high as 26.9%. However, the same blouse added a pocket or two below the waist would instead be classified as a different product and subject to only a 16.0% tariff rate. Nevertheless, using tariff engineering requires substantial financial and human resources, which often were beyond the affordability of small and medium-sized fashion companies.

Third, recognizing the negative impacts of Section 301 on US businesses and consumers, the Office of the US Trade Representative (USTR) created a so-called “Section 301 exclusion process.” Under this mechanism, companies could request that a particular product be excluded from the Section 301 tariffs, subject to specific criteria determined at the discretion of USTR. The petition for the product exclusion required substantial paperwork, however. Even companies with an in-house legal team typically hire a DC-based law firm experienced with international trade litigation to assist the petition, given the professional knowledge and a strong government relation needed. Also of concern to fashion companies was the low success rate of the petition. The record showed that nearly 90 percent of petitions were denied for failure to demonstrate “severe economic harm.” Eventually, since the launch of the exclusion process, fewer than 1% of apparel items subject to the Section 301 punitive tariff were exempted. Understandably, the extra financial burden and the long shot discouraged fashion companies, especially small and medium-sized, from taking advantage of the exclusion process.

In conclusion, with USTR’s latest announcement, the debate on Section 301 and the outlook of China as a textile and apparel sourcing base will continue. Notably, while economic factors matter, we shall not ignore the impact of non-economic factors on the fate of the Section 301 tariff action against China. For example, with the implementation of the Uyghur Forced Labor Prevention Act (UFLPA), only about 10% of US cotton apparel imports came from China in the first ten months of 2022 (latest data available), the lowest in a decade.  As the overall US-China bilateral trade relationship significantly deteriorated in recent years and the friction between the two countries expanded into highly politically sensitive areas, the Biden administration could “willfully” choose to keep the Section 301 tariff as negotiation leverage. Domestically, President Biden also didn’t want to look “weak” on his China policy, given the bipartisan support for taking on China’s rise.

by Sheng Lu

Suggested citation: Lu, S. (2022). US-China Tariff War and Apparel Sourcing: A Four-Year Review. FASH455 global apparel and textile trade and sourcing. https://shenglufashion.com/2022/09/10/us-china-tariff-war-and-apparel-sourcing-a-four-year-review/

Utilization of US Trade Preference Programs–Why Fashion Companies Make the Sourcing Decisions They Do? (Video recording)

2022 WTO Aid for Trade Conference

Part 1 – Exporting countries and utilization of US Trade Preference Programs: An Overview

Part 2. Case Studies: Why companies make the sourcing decisions they do?

  • Patrick Fox, Senior Director, Customs and Trade Strategy, VF Corporation
  • Cen Williams, Hub Leader for Africa and Middle East region, PVH
  • Greg Poole, Chief Sourcing Officer, The Children’s Place

Background:

Trade preference programs provide duty-free US market access to selected exports of eligible developing countries. Unlike free trade agreements, all preference programs are unilateral, meaning they do not require reciprocal trade concessions.

There are five major trade preference programs enacted in the United States, including:

  • Generalized System of Preferences (GSP), which applies to developing countries as a whole. However, the US GSP program excludes most textile and apparel products due to import competition concerns.  GSP expired on December 31, 2020 and Congress is working with stakeholders to renew the program.
  • Four trade preference programs that target specific regions, including the Andean Trade Preference Act (APTA), the Caribbean Basin Economic Recovery Act (CBERA), the Caribbean Basin Trade Partnership Act (CBTPA), the African Growth and Opportunity Act (AGOA), and the Haitian Opportunity through Partnership Encouragement (HOPE) Act. In 2021, about 2% of US apparel imports came from trade preference partners.
  • US trade preferences reflect both economic development and foreign policy goals. In addition to the economic benefits, eligibility criteria create incentives for beneficiary countries to support objectives such as adopting and enforcing internationally recognized worker rights, reducing barriers to investment, and enforcing intellectual property rights.
  • However, the trade preference program is not without controversies. For example, it is debatable whether the trade preference program effectively enhances the genuine export competitiveness of developing countries. Also, despite preferential duty benefits, US fashion companies often hesitate to source more from trade preference partners due to concerns about a lack of critical infrastructure, limited production capacity, and political instability.

Unlocking RCEP for Business: Opportunities for Garment and Textile Industry [Webinar]

The event is hosted by the Association of Southeast Asian Nations (ASEAN) Secretariat.

About the webinar: This webinar seeks to understand the opportunities offered by the Regional Comprehensive Economic Partnership (RCEP) Agreement for the garment and textile industry in the region. Considering that the garment and textile industry involves a large number of MSMEs in its supply chain, it would be important to understand how MSMEs can utilise the RCEP Agreement to grow their business and further integrate themselves into the global supply chain, noting that RCEP members are critical apparel-sourcing country for many big global players in the industry.

The first part of the event includes three presentations. 1) textile and apparel trade patterns in the RCEP region and how to read RCEP’s detailed tariff phaseout schedule. 2) RCEP rules of origin for textiles and apparel; and 3) customs procedure

In the second half, three companies from Cambodia, Thailand, and Indonesia shared their perspectives about the potential impact of RCEP on their businesses.

Speakers:

  • Dr. Sheng Lu, Associate Professor, Department of Fashion and Apparel Studies, University of Delaware (presentation starts at 17m41s)
  • Mr. Chy Sotharith, Chief of Non-Tariff Measures and Export-Import Policy Bureau, Department of Export-Import, General Department of Trade Support Services, Ministry of Commerce, Cambodia
  • Ms. Suchaya Chinwongse, Former Expert of Rules of Origin, the Customs Department of Thailand
  • Mr. Prama Yudha Amdan, Head of Corporate Communications and PR, Assistant President Director Asia Pacific Fibers
  • Mr. Kaing Monika Deputy Secretary General of Garment Manufacturers Association in Cambodia (GMAC)
  • Mr. Jumnong Nawasmittawong, Executive Advisory Board to Textile Industry Club, The Federation of Thai Industries.

US Apparel Imports Face Growing Market Uncertainties (Updated: June 2022)

(See updated analysis: Patterns of US Apparel Imports in the First Half of 2022 and Key Sourcing Trends)

The latest trade data shows that in the first four months of 2022, US apparel imports increased by 40.6% in value and 25.9% in quantity from a year ago. However, the seemingly robust import expansion is shadowed by the rising market uncertainties.

Uncertainty 1: US economy. As the US economic growth slows down, consumers have turned more cautious about discretionary spending on clothing to prioritize other necessities. Notably, in the first quarter of 2022, clothing accounted for only 3.9% of US consumers’ total expenditure, down from 4.3% in 2019 before the pandemic. Likewise, according to the Conference Board, US consumers’ confidence index (CCI) dropped to 106.4 (1985=100) in May 2022 from 113.8 in January 2022, confirming consumers’ increasing anxiety about their household’s financial outlook.

Removing the seasonal factor, US apparel imports in April 2022 went up 2.8% in quantity and 3.0% in value from March 2022, much lower than 9.3% and 11.9% a month ago (i.e., March 2022 vs. February 2022). The notable slowed import growth reflects the negative impact of inflation on US consumers’ clothing spending. According to the Census, the value of US clothing store sales marginally went up by 0.8% in April 2022 from a month ago, also the lowest so far in 2022.

Apparel import price index

Uncertainty 2: Worldwide inflation. Data from the Bureau of Economic Analysis shows that the price index of US apparel imports reached 103.1 in May 2022 (May 2020=100), up from 100.3 one year ago (i.e., a 2.8% price increase). At the product level (i.e., 6-digit HS Code, HS Chapters 61-62), over 60% of US apparel imports from leading sources such as China, Vietnam, Bangladesh, and CAFTA-DR experienced a price increase in the first quarter of 2022 compared with a year ago. The price surge of nearly 40% of products exceeded 10 percent. As almost everything, from shipping, textile raw materials, and labor to energy, continues to soar, the rising sourcing costs facing US fashion companies are not likely to ease anytime soon.

The deteriorating inflation also heats up the debate on whether to continue the US Section 301 tariff action against imports from China. Since implementing the punitive tariffs, US fashion companies have to pay around $1 billion in extra import duties every year, resulting in the average applied import tariff rate for dutiable apparel items reaching almost 19%. Although some e-commerce businesses took advantage of the so-called “de minimis” rule (i.e., imports valued at $800 or less by one person on a day are not required to pay tariffs), over 99.8% of dutiable US apparel imports still pay duties.

Uncertainty 3: “Made in China.” US apparel imports from China in April 2022 significantly dropped by 26.7% in quantity and 24.6% in value from March 2022 (seasonally adjusted). China’s market shares also fell to a new record low of 26.3% in quantity and 16.8% in value in April 2022. The zero-COVID policy and new lockdown undoubtedly was a critical factor contributing to the decline. Fashion companies’ concerns about the trajectory of the US-China relations and the upcoming implementation of the new Uyghur Forced Labor Prevention Act (UFLPA) are also relevant factors. For example, only 10.5% of US cotton apparel imports came from China in April 2022, a further decline from about 15% at the beginning of the year. Given the expected challenges of meeting the rebuttable presumption requirements in UFLPA and the high compliance costs, it is not unlikely that US fashion companies may continue to reduce their China exposure.

As US fashion companies source less from China, they primarily move their sourcing orders to China’s competitors in Asia. Measured in value, about 74.8% of US apparel imports came from Asia so far in 2022 (January-April), up from 72.8% a year ago. In comparison, there is no clear sign that more sourcing orders have been permanently moved to the Western Hemisphere. For example, in April 2022, CAFTA-DR members accounted for 9.3% of US apparel imports in quantity (was 10.8% in April 2021) and 10.2% in value (was 11.4% in April 2021).

Uncertainty 4: Shipping delays. Data suggests we are not out of the woods yet for shipping delays and supply chain disruptions. For example, as Table 2 shows, the seasonable pattern of US apparel imports in March 2022 is similar to January before the pandemic (2017-2020). In other words, many US fashion companies still face about 1.5-2 months of shipping delays. Additionally, several of China’s major ports were under strict COVID lockdowns starting in late March, including Shanghai, the world’s largest. Thus, the worsened supply chain disruptions could negatively affect the US apparel import volumes in the coming months.

by Sheng Lu

Further reading: Lu, S. (2022). Myanmar loses appeal for US apparel imports. Just-Style.

Summary of CRS Reports in 2022: Selected Key Trade Issues for US Congress

US-China Phase One Trade Deal

Congress might assess the U.S. experience with the Phase One process as it debates the merits of the deal and how to leverage it, the effects of the tariffs, and options to advance U.S. economic interests and counter China’s persistent statist economic practices. Specifically:

  • In light of how difficult it was to secure China’s acknowledgment of its practices of concern and limited commitments in these areas, to what extent may the U.S. reasonably expect talks with Beijing to achieve outcomes that further U.S. policy objectives, when measured against the U.S. resources and efforts required? Does focusing on talks with China take U.S. focus and resources away from efforts to deploy or develop U.S. trade tools and joint approaches with other countries that might be required to protect and advance U.S. economic interests?
  • Is the executive branch fully using its authorities to address its concerns about China? Are other approaches and measures needed in addition to or separate from tariffs, and if so, what are they? Should the USTR use Section 301 to address other concerns, such as subsidies? What approaches could be pursued, such as prior efforts with Europe and Japan to address non-market economic distortions and subsidies?
  • Should Congress require the USTR to enforce the Phase One provisions and actively use the Phase One dispute process? Should the USTR challenge China’s industrial policies that appear to violate commitments not to require technology transfer, and its efforts to set global technology licensing and pricing terms, such as through its courts?
  • How might Congress weigh the tariffs’ effects on U.S. firms and consumers against issues of economic competitiveness? To what extent are tariffs inflationary compared to drivers such as food, energy, housing, labor and supply chain shortages, and monetary policy?
  • Could tariffs help diversify China-based supply chains and counter China’s subsidies by raising costs vis-à-vis U.S. and third-market products? Could tariffs on goods tied to China’s industrial policies help level the playing field, or would this violate U.S. trade commitments and encourage others to follow suit? USTR proposed but never enacted tariffs on consumer electronics. Could these tariffs counter China’s efforts to deepen technology supply chains in China?

Section 301 Exclusions on US Imports from China

Congress could engage with the Administration to develop and implement guidelines for when and how to grant and extend exclusions. This could potentially promote transparency, consistency, and proper application of standards in reviewing requests, thereby helping to ensure that the USTR carries out Section 301 objectives as prescribed by Congress

Indo-Pacific Economic Framework (IPEF)

  • What role should Congress play in the negotiation and consideration of an IPEF and other regional trade initiatives? What regional and other multilateral trade commitments would best serve U.S. economic and strategic interests in the region?
  • What types of enforcement mechanisms would an IPEF include and how would its commitments and enforceability compare to CPTPP and U.S. free trade agreements? What are the tradeoffs of these approaches and should they be pursued in tandem?
  • How does the expiration of U.S. Trade Promotion Authority (TPA) affect the Administration’s approach to scoping, negotiating, and enacting an IPEF and trade agreements?

Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP)

  • What are the costs and benefits of different approaches to regional economic engagement (CPTPP, IPEF, RCEP)? Should other approaches be considered?
  • What scope exists for changes to CPTPP if the United States were to consider joining, and what are the implications of China’s potential membership?

African Growth and Opportunity Act (AGOA)

  • AGOA reauthorization. AGOA is authorized through September 2025. US Trade Representative Katherine Tai has urged consideration of improvements to encourage investment, and help small and women-owned businesses and more countries make use of the program. Congress may consider whether and when to reauthorize AGOA and if reforms are needed.
  • Free trade agreement (FTA) negotiations. An FTA with an AGOA-eligible country would have implications for AGOA and U.S. trade relations in the region. As the Administration, in consultation with Congress, determines whether to pursue trade negotiations in the region, including with Kenya, key considerations include: (1) what flexibilities from typical U.S. FTA commitments are appropriate; (2) potential effects on broader AGOA utilization; and (3) potential effects on regional initiatives like the African Continental Free Trade Area(AfCFTA).
  • Increased U.S. tariffs. The Trump administration imposed tariff increases (Section 232) on steel and aluminum imports. Congress may examine the tariffs’ effects on AGOA participants.
  • Third-party agreements. Reciprocal agreements between AGOA beneficiaries and third parties (e.g., EU-South Africa) may disadvantage U.S. exporters. Congress may examine possible U.S. responses.

US-Kenya Free Trade Agreement Negotiation

Congress may consider and advise the Administration on how to prioritize free trade agreement (FTA) talks with Kenya among other U.S. trade policy objectives; whether and in what form to seek renewal of the Trade Promotion Authority (TPA); the scope and extent of potential U.S.-Kenya FTA commitments to pursue; how to ensure an FTA with Kenya and its rules of origin support regional integration efforts and U.S. economic interests; and the potential types of support (e.g., trade capacity building funds) and flexibilities (e.g., phasing in of commitments) to include as appropriate to Kenya’s level of development)

U.S.-UK Trade Relations

Congress may continue to monitor U.S. trade and economic interests at stake in the UK-EU Trade and Cooperation Agreement (TCA)’s implementation. It may consider whether to press the Administration to continue to prioritize resolving specific trade issues and/or renew broader U.S-UK free trade agreement negotiations. In doing so, Congress may examine the potential benefits and costs of further U.S.-UK trade liberalization (or its absence) for the firms and workers in their districts and states.

Many in Congress and in the U.S. industry support a U.S.-UK FTA. Many Members tie their support to ensuring that Brexit outcomes do not undermine the Northern Ireland peace process. A potential TPA renewal debate could heighten these issues. If FTA talks proceed, Congress may monitor and shape them, and consider implementing legislation for a final agreement. Additionally, Members may examine other ways to engage further on bilateral and global trade issues of shared concern, e.g., sectoral regulatory cooperation or dialogues.

Generalized System of Preferences (GSP) Reauthorization and Reform

The GSP program expired on December 31, 2020. Congress is considering several bills to reauthorize and introduce new eligibility criteria to the program. Some of the proposed eligibility criteria include provisions on human rights, environmental laws, and good governance. Supporters of the proposed eligibility criteria consider it a modernization of the GSP program to address modern-day issues. Others raise concerns that adding new criteria may make the costs of complying with the program outweigh the benefits and discourage beneficiary developing countries’ participation. They may also undermine the core objectives of the program, which is to promote economic development through trade.

Other possible options for GSP include:

  • Support reciprocal tariff and market access benefit through free trade agreements (FTAs). Some U.S. policymakers have suggested that developing countries might benefit more through WTO multilateral negotiations, FTAs, or some form of agreement that could also provide reciprocal trade benefits and improved market access for the United States.
  • Authorize GSP only for Least-Developed Countries (LDCs). Narrowing the scope of eligibility could benefit the LDC that remains in the program by reducing competition in the U.S. market from more advanced developing countries. Assuming that many LDCs would continue to receive the GSP preference under AGOA, other LDCs that might benefit from an LDC-only GSP program are Afghanistan, Bhutan, Burma, Burundi, Cambodia, Congo (Kinshasa), Haiti, Kiribati, Mauritania, Nepal, Samoa, Somalia, South Sudan, the Solomon Islands, Timor-Leste,Tuvalu, and Vanuat.
  • Expand the application of GSP. For example, allow some import-sensitive products to receive preferential access (such as apparel). Increase the flexibility of rules of origin (ROO) requirements. For example, allow more GSP beneficiaries to cumulate inputs with other beneficiaries to meet the 35% domestic content requirement or lower the domestic content requirement. Eliminate competitive need limitations or raise the thresholds. Reauthorize GSP for longer terms or make the program permanent.
  • Restrict Application of Preferences. For example: Consider mandatory graduation for “middle income.” Strengthen provision that allows graduation of individual industry sectors within beneficiary countries. Reform eligibility criteria to strengthen provisions on worker rights as well as introduce new criteria, such as good governance, gender equality, and environmental law and regulation.

U.S.-EU Trade and Technology Council (TTC)

Congress may examine and weigh in on the TTC’s structure, priorities and scope, and prospects for “success.”

  • TTC’s anticipated prioritization of more recent or urgent issues (such as joint responses to Russia’s aggression in Ukraine), compared to other bilateral trade and technology issues (such as digital inclusion) that were priorities at the time of the TTC launch. Congress may explore potential trade-offs in priorities and/or opportunities to expand the TTC, such as by creating additional working groups or structures to sustain intensified cooperation on major bilateral trade issues. This may include a review of whether to modify the scope of the TTC’s working groups to address bilateral tariffs and other market access issues. Congress also may explore opportunities through the TTC to intensify U.S.-EU cooperation to remove regulatory barriers.
  • Congress may examine the TTC’s prospects for success and its ability to produce concrete outcomes, and also seek to establish the metrics by which to gauge the TTC’s effectiveness.

Congress may examine whether to pursue potential market opening opportunities through the TTC for future formal US-EU FTA talks, or pursue such talks separately. On one hand, potential FTA negotiations that develop out of the TTC could benefit from the intensified cooperation and renewed trust that the TTC may foster. On the other hand, such talks may be limited if they do not address bilateral tariffs or other market access issues.

Appendix: List of CRS reports on trade issues

Video discussion: How Fashion Companies Design Products To Avoid Tariffs

Background: Tariff engineering refers to the practice of designing a product (e.g., clothing) to be classified at a lower tariff rate. For example, “women’s or girls’ blouses, shirts, and shirt-blouses of man-made fibers” imported from China can get taxed as high as 26.9%. However, the same blouse added a pocket or two below the waist would instead be classified as a different product and subject to only a 16.0% tariff rate.

US fashion companies like Columbia Sportswear leveraged tariff engineering to mitigate the negative impact of the US-China tariff war. Nevertheless, using tariff engineering requires substantial financial and human resources, which often were beyond the affordability of small and medium-sized fashion companies.

Discussion questions:

What do you think about tariff and tariff engineering based on the video and our lectures?