Fashion Intel & Analysis

In This Memo:

  • GSP Set to Expire on December 31st
  • Commerce Issues Affirmative Preliminary Anti-Dumping Duty Determinations on Certain Polyester from China
  • CBP Announces Value-Added Quota for Haiti HELP

GSP Set to Expire on December 31st

On December 31st, the Generalized System of Preferences (GSP) is set to expire, barring any last-minute action by Congress.

According to CBP, “Once GSP lapses and until further notice, importers will be required to pay duties on all otherwise-GSP importations, but should continue to flag these entries with the appropriate special program indicator ‘A’ until Congress reauthorizes the program. In the event that Congress retroactively reauthorizes the program, as was done with previous lapses, CBP will refund duties paid during the lapse period.” We understand CBP is working to handle the lapse with “minimum disruption” to trade, and any repayment of duties will be done in “an automated, efficient, and expeditious manner.” More detailed guidance is available in the CBP Cargo Messaging Service.

Commerce Issues Affirmative Preliminary Anti-Dumping Duty Determinations on Certain Polyester from China

The U.S. Department of Commerce announced this week the affirmative preliminary determinations in the anti-dumping duty investigations of imports of fine denier polyester staple fiber, finding that exporters from China, India, Korea, and Taiwan have sold this merchandise at less than fair value. Commerce will instruct U.S. Customs & Border Protection (CBP) to collect cash deposits from the importers from China (52.66 percent to 170.92 percent), India (0.66 percent to 15.66 percent), Korea (0.0 percent to 45.23 percent) and Taiwan (0.0 percent to 48.86 percent) based on these preliminary rates. More information is available in the Commerce Department fact sheet. 

CBP Announces Value-Added Quota for Haiti HELP

On December 20th, the U.S. government announced the new quota for the Haiti HELP “value-added” program, which requires that apparel meet a minimum threshold percentage of value added in Haiti, the United States, and/or certain beneficiary countries. The program is subject to a quota, calculated as a percentage of total imports into the United States for each 12-month annual period. For the annual period from December 20, 2017, through December 19, 2018, the quantity of imports eligible for preferential treatment under the value-added program is 361,603,339 SME. More information is available on the U.S. Customs & Border Protection website.

On December 18th, President Trump announced a new “America First” national security strategy, focusing on four main themes: “Protecting the American People, the Homeland, and the American Way of Life,” “Promote American Prosperity,” “Preserve Peace through Strength,” and “Advance American Influence.” In his speech announcing the new strategy, he specifically called out trade, stating, “Our leaders in Washington negotiated disastrous trade deals that brought massive profits to many foreign nations, but sent thousands of American factories and millions of American jobs to those other countries.” The strategy will focus on three “key regions”: Indo-Pacific (“which stretches from the west coast of India to the western shores of the United States, represents the most populous and economically dynamic part of the world.”), Europe, and the Middle East. The full strategy and a summary are available on the White House website.

In This Memo:

  • East Coast Trade Symposium Registration Opens Today
  • USTR Announces New GSP Enforcement Priorities

East Coast Trade Symposium Registration Opens Today

U.S. Customs & Border Protection will host the East Coast Trade Symposium on December 5-6, 2017, in Atlanta. The event will cover de minimis (section 321), facilitation and enforcement, interagency import safety, Western Hemisphere enforcement, and more. Registration will open today, Thursday, October 26th at noon ET. This event usually sells out, so we encourage you to register early if you plan to attend! Visit for details.

And don’t forget to register to join us on November 15th in New York City to hear from Mitchel Landau, Assistant Director, Validation & Compliance Division at the U.S. Customs & Border Protection Center for Excellence & Expertise (CEE) for Apparel, Footwear, & Textiles, and Deborah Marinucci, Branch Chief, National Commodity Specialist Division, Regulations & Rulings, U.S. Customs & Border Protection Office of Trade. Visit for details.

USTR Announces New GSP Enforcement Priorities

On October 25th, U.S. Trade Representative Robert Lighthizer announced new enforcement priorities to ensure beneficiaries are meeting eligibility criteria for the Generalized System of Preferences (GSP). According to the USTR press release:

This new effort includes a heightened focus on concluding outstanding GSP cases and a new interagency process to assess beneficiary country eligibility. This interagency process complements the current petition receipt and public input process for country practice reviews, which will remain unchanged. 

The new additional process will involve a triennial assessment by USTR and other relevant agencies of each GSP beneficiary country’s compliance with the statutory eligibility criteria. If the assessment of a beneficiary country raises concerns regarding the country’s compliance with an eligibility criterion, the Administration may self-initiate a full country practice review of that country’s continued eligibility for GSP. The first assessment period will focus on GSP beneficiary countries in Asia.

More information is available on the USTR website.

In This Memo:

Senate Confirms DHS Secretary Nielsen

On December 5th, the U.S. Senate voted to confirm Kirstjen Nielsen as the sixth Secretary of Homeland Security. Nielsen is a close confidant of White House of Chief of Staff John Kelly, working as his deputy in the White House and previously at DHS. According to the Washington Post, “An attorney and cybersecurity expert, Nielsen will be the first DHS secretary with previous experience working at the agency. Her confirmation Tuesday gives the White House a DHS chief well versed in the politics and policy goals of Trump’s immigration enforcement agenda.”

United States & Egypt Agree to Further Trade Cooperation

On December 5th, the United States and Egypt Trade and Investment Council met in Cairo to discuss ways to further expand fair and reciprocal trade and investment between the two countries. According to the statement from the Office of the U.S. Trade Representative (USTR),

The United States used the meeting to update Egypt on the Administration’s priorities on trade, including opening markets and enforcing trade rules. The United States also underscored the importance the Administration places on deepening trade ties with countries in the Europe and Middle East region, including Egypt.

The Council acknowledged the importance of improving the overall private sector business climate facing U.S. and Egyptian companies. During the meeting, U.S. and Egyptian officials agreed to work together to address outstanding bilateral trade issues, including those related to market access, standards, labor, and intellectual property protection. They agreed to devise wherever possible new ways to promote trade between the two nations.

The full statement is available on the USTR website.

Public Radio International Tool Shows “Fairness” of Fashion

Public Radio International (PRI) has launched a new series this week called “Wear and Tear,” examining social compliance and sustainability issues in the fashion industry. As part of the series, PRI has launched a tool, How Fair Is Your Fashion?, in which readers can “grade” their clothes by selecting the brand, type of garment, and factory location and getting details on the sustainability of the product. The series and tool are available on the PRI website.

Business Economists Say Trade Protectionism Top Risk

Reflecting the sentiment we heard at our annual conference last month in New York, the National Association of Business Economists (NABE) has released a new study showing that 25 percent of business economists say “trade protectionism” is the top risk to the U.S. economy in 2018, beating higher interest rates, stock market decline, immigration restrictions, a strong U.S. dollar, and weak wage growth. The respondents forecast average inflation-adjusted GDP growth of 2.2 percent for 2017 and 2.5 percent for 2018. The survey is available on the NABE website.

Today on Capitol Hill, the United States Fashion Industry Association (USFIA) joined with other fashion and retail associations and companies, to launch the U.S. Global Value Chain Coalition, including a new study showcasing the fact that millions of American jobs rely on the U.S. global value chain and contribute to the American economy. The Coalition’s founding members include USFIA Board members Levi Strauss & Co., Macy’s, and SanMar.

The study found that the U.S. average value-added exceeded 70 percent for the products analyzed. Making use of the global marketplace for the 98 percent of the apparel sold in the United States enables American companies to offer consumers the widest variety of apparel at the best prices while supporting millions of medium-to high-skilled jobs. The research also shows that tariffs routinely applied to apparel imports are among the highest levied on any industry, and can result in higher prices for consumers. The Coalition is committed to supporting policies that recognize the benefits of free trade that can help lower prices for consumers, increase demand and create more American jobs.

The full study is available here.

Individual companies’ one-pagers explaining how they create jobs in the United States with global value chains are available here.

For more information, visit Contact us if you’re interested in getting involved in the Coalition!