The following is an excerpt....
Julie Hughes, president of the United States Fashion Industry Association (USFIA), says most companies anticipated that the administration would use forced labor-related Section 301 tariffs to maintain 10% or 12.5% duties, after the temporary Section 122.
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This is reshaping sourcing strategies, too. In USFIA’s 2026 Fashion Industry Benchmarking Study, released last month and led by University of Delaware professor Sheng Lu with Emilie Delaye, protectionist US trade policies and tariff uncertainty ranked as companies’ top business challenges. About 62% of respondents expressed optimism about the industry’s next five years, the lowest level recorded since the study began tracking that measure, Lu says.
That dynamic is also making China harder to replace than the politics of pro-China decoupling might suggest. For most China-origin goods, the all-in tariff burden can now run from the high 20s into the 40%-plus range, once ordinary duties, legacy China tariffs and the new forced labor levy are combined. Lu says China’s sourcing cost competitiveness improved in this year’s survey, while it continued to lead on flexibility, agility, minimum order quantities and vertical integration. More than 70% ofrespondents sourced fabrics and textile accessories such as buttons, zippers, trims and labels from China, while 65% sourced yarns and threads there. The share of respondents planning to reduce China sourcing fell from more than 80% in 2024 and 2025 to 40% this year; about 20% planned to increase sourcing from China, up from 6% in 2025.
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The USMCA still appears to offer some protection. Hughes says USMCA-qualifyingproducts are exempt from the forced labor Section 301 tariffs, and textile and apparel provisions do not currently appear to be under negotiation. That protection does not resolve the separate Canada-specific Section 338 threat, but it does suggest USMCA treatment still matters in parts of the tariff regime. But that doesn’t mean the region is in the clear. “I don’t know that we can call any place ‘safe’,” she says. USFIA is working with the AAFA and the National Council of Textile Organizations on a Western Hemisphere Initiative that would support US textiles, CAFTA-DR and USMCA apparel production and tariff relief for brands and retailers. “It’s not a panacea,” Hughes adds, “but that is a start.”
The Forced Labor Question
The forced labor rationale has raised another concern: whether tariffs are the right enforcement tool. Lu says tariffs do not help companies manage forced labor risk; instead, they can reduce resources available for sustainability and compliance. In the USFIA survey, 53% of respondents said higher tariff burdens forced them to reduce financial resources for critical areas such as sustainability.
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