Fashion Intel & Analysis

Posted on the Office of the U.S. Trade Representative (USTR) website is a new notice granting product exclusions for 146 products that appear on List 3 of the China 301 tariffs. The list includes several textile and travel goods, which are included below by HTS number.  In addition there are a number of exclusions granted for kitchen articles in Chapter 73 and furniture in Chapter 94.  The product exclusions will apply retroactively from September 24, 2018 and will extend to August 7, 2020.

3401.30.5000, Disposable cloths of nonwoven textile materials impregnated, coated or
covered with organic surface-active preparations for washing the skin, put up
for retail sale

4202.92.3120, Backpacks with outer surface of textile materials of man-made fibers, each
with padded and insulated zippered compartments measuring not more than
27 cm by 19 cm by 21.5 cm

4202.92.3131, Cases of textile materials of man-made fibers, each measuring not more than
57 cm by 47 cm by 34 cm, specially fitted to contain a sewing machine, each 
 with outer pockets, side handles and 4 wheels 

4202.92.9100, Cases of man-made fiber, each measuring not more than 40 cm by 27 cm by 9
cm, with clear zippered pockets, mesh pockets and a carrying handle

5208.39.2020, Dyed sateen fabric containing at least 85 percent by weight of cotton,
measuring at least 292 cm but not more than 293 cm in width, weighing not
more than 210 g/m² 

 In an analysis of the latest trade statistics from the Office of Textiles and Apparel at the Department of Commerce (OTEXA), Dr. Sheng Lu at the University of Delaware looked at the impact of COVID-19. U.S. Apparel imports from January to March have dropped 12% compared to 2019. We are also seeing sharp declines in China's apparel exports to the United States which declined 52.4% in March compared to March 2019. This shift is also marked by Vietnam's emergence as the top apparel supplier to the United States in March of 2020. This is the first time in history that Vietnam's market share of U.S. apparel imports has surpassed China. It is clear brands and retailers are looking outside of China for alternate sourcing destinations, however according to Lu, "no clear evidence has suggested that U.S. fashion brands and retailers are giving more apparel sourcing orders to suppliers from the Western Hemisphere."

In a message (CSMS #42590577), U.S. Customs and Border Protection provides guidance on filing entries for importing hand sanitizers. Hand sanitizers are considered a drug and are therefore regulated by the Food and Drug Administration (FDA). The FDA is temporarily allowing firms to register as over-the-counter drug manufacturers to manufacture hand sanitizer for the duration of the public health crisis. These temporary measures still require importers to file entries of hand sanitizers with the FDA and provide the appropriate data for over-the-counter products. More information on the drug importation process can be found on the FDA website, and more information on ACE requirements can be found here

In a joint statement from U.S. Trade Representative Robert Lighthizer and U.K. Secretary of State for International Trade Elizabeth Truss formally announced the launch of trade negotiations between the two countries. In respect to COVID-19 concerns, the first round of negotiations will be conducted virtually. Lighthizier was quoted saying "the United States will negotiate an ambitious and high-standard trade agreement with the UK that will strengthen our economies, support good-paying jobs and substantially improve opportunities for trade and investment between our two countries." Truss said “The US is our largest trading partner and increasing transatlantic trade can help our economies bounce back from the economic challenge posed by Coronavirus."

The United States International Trade Commission (USITC) released a database of imported products needed for the COVID-19 response. This database comes at the request of the House Ways and Means Committee and the Senate Finance Committee and contains trade-related information for products needed for the COVID-19 response. In a letter to the USITC, asking the Commission to create the database, Chairman Richard Neal of the House Ways and Means Committee and Chairman Charles Grassley of the Senate Finance Committee said " As we grapple with the challenges presented by the novel coronavirus, we are keenly aware that our challenges are being severely exacerbated by disruptions and deficiencies in our supply of equipment, inputs, and substances needed for treating and otherwise responding to the COVID-19 pandemic."

For each product identified the database will contain the following information:  

  • its description

  • general duty rate

  • any special or additional rates of duty imposed on the article, and the dates on which the rates were imposed, and the authorities under which they were imposed

  • whether any such duties have been suspended and, if so, the date of suspension as well how the long suspension is scheduled to last

  • the total range of duty rates imposed on such articles, including any special or additional rate of duty

  • the major countries of origin for each HTS number identified, and the import value of that HTS number from each country for the years 2017-2019.