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AAFA Testimony and Comments 2003 and prior
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| 2003 Comments | 2002 Comments | 2001 & Before Comments |
AAFA released a new study December 10 (report, press release) assessing the competitiveness of the Central American apparel industry. The report found that a commercially-meaningful U.S.-Central America Free Trade Agreement (FTA) is crucial to the future survival and viability of the Central American industry. The release of the report is timely, as the final set of negotiations on the FTA have begun in Washington, DC. Posted December 10, 2003.
AAFA joined with Wal-Mart, Target, Payless and a number of retailer associations in urging the U.S. government to negotiate a strong footwear provision in the proposed U.S.-Central America Free Trade Agreement (FTA). The December 8 letter, sent on the eve of the final set of FTA negotiations, urges the United States to negotiate a simple, flexible rule of origin (substantial transformation) for ALL footwear, except 17 specific rubber/fabric and plastic/protective footwear items. Such a provision would help Central America become an important sourcing hub for footwear. Posted December 9, 2003
AAFA President and CEO Kevin M. Burke joined with the Presidents of three other trade associations in a sending a December 1 letter to President George W. Bush to alert the Administration to a problem that will occur at the end of 2004 when there will be insufficient quota to cover U.S. clothing market needs. The letter notes that, because there is reduced quota flexibility during 2004, many countries will actually have smaller quotas in that year than in previous years. This could result in significant disruption during the final months of 2004. The letter urges the Administration to adjust 2004 quota levels upward soon to accommodate this artificial shortage. Posted December 9, 2003.
AAFA President and CEO Kevin M. Burke submitted comments to the U.S. Department of Homeland Security's Bureau of Customs and Border Protection on December 1 on Customs' interim regulations affecting the production of brassiere under the Caribbean Basin Trade Partnership Act (CBTPA). In the comments, Burke asked for clarification to ensure that changes made by Congress to CBTPA's brassiere provisions during 2002 are more fully accommodated in the final regulations. Posted December 9, 2003.
AAFA joined with over fifty other major companies and organizations in sending a November 17 letter to the Senate leadership strongly opposing proposed legislation that would have imposed additional 27.5 percent duties on all U.S. imports from China in retaliation for China's alleged undervaluation of its currency. Posted March 3, 2004.
AAFA joined with a coalition of apparel, textile and retail associations to send a November 13 letter to members of the House and Senate Appropriations Committees strongly urging Congress to include a provision in appropriations legislation permitting the U.S. government to provide export financing and insurance for U.S. apparel imports that use U.S.-made textiles. The language proposed in the letter would strongly encourage the U.S. Export-Import Bank (Ex-Im Bank) Trade and Development Agency (TDA) and the Overseas Private Investment Corporation (OPIC) to provide financing to U.S. textile, apparel and retail firms that import apparel into the United States using U.S. inputs under U.S. trade preference programs and free trade agreements, such as the Caribbean Basin Trade Partnership Act (CBTPA), the North American Free Trade Agreement (NAFTA) and the African Growth and Opportunity Act (AGOA). The Ex-Im Bank TDA and OPIC currently do not provide financing in the textile and apparel industries because of stated policy that it will not enter "sensitive" industries. Posted November 17, 2003.
AAFA sent a letter November 12 to all five Central American trade ministers (Costa Rica, El Salvador, Guatemala, Honduras and Nicaragua) on the footwear provisions in the proposed U.S.-Central America Free Trade Agreement (FTA). The letter emphasizes the overwhelming importance of implementing the footwear agreement reached last year between AAFA and the Rubber and Plastics Footwear Manufacturers Association (RPFMA) in the proposed U.S.-Central America FTA. If the U.S.-Central America FTA includes the AAFA/RPFMA footwear agreement, virtually all U.S. footwear imports from Central America would enter the United States duty-free under very flexible rules of origin (i.e. substantial transformation). Only 17 specific rubber/fabric and plastic/protective footwear items (described in detail in the attachment to this letter) would still be subject to the more restrictive rules of origin that currently exists under the Caribbean Basin Trade Partnership Act (CBTPA). Since the United States plans to dock the Dominican Republic into a U.S.-Central America FTA, these same provisions would then apply to U.S. footwear imports from the Dominican Republic. AAFA reached this agreement with RPFMA to ensure that well over 95% of all U.S. footwear imports (including 100% of the current footwear imports from Central America) would enter the United States duty-free under flexible rules of origin while protecting many of the footwear items still produced in the United States. As long as the AAFA/RPFMA agreement is embodied in the final U.S.-Central America FTA, RPFMA has guaranteed that they will not use its formidable allies in Congress to fight the U.S.-Central America FTA when it comes before Congress this summer. Although AAFA has worked closely with the U.S. negotiators to ensure that this agreement is part of the U.S.-Central America FTA, we have recently learned that some in the Central American footwear industry have balked at this proposal. As a result, AAFA has been working with its contacts in the region and have sent this letter to the Central American trade ministers outlining the importance, both political and economic, of ensuring that the AAFA/RPFMA footwear agreement is included in the final U.S.-Central America FTA.
In a November 6 letter to 165 members of Congress, AAFA joined with the National Retail Federation (NRF), the International Mass Retailers Association (IMRA) and the U.S. Association of Importers of Textiles and Apparel (USA-ITA) to argue against Congressional support for measures against China and for a restrictive U.S.-Central America Free Trade Agreement (FTA) will do nothing to save the U.S. textile industry. The association letter is a response to an October 29 letter authored by the 165 members of Congress and sent to President George W. Bush demanding that the U.S. government impose safeguard quotas on U.S. imports of Chinese brassieres, dressing gowns and knitted fabrics and demanding a strict yarn-forward rule of origin for apparel in the U.S.-Central America FTA. The association letter notes that imposition of safeguard quotas will do nothing to bring manufacturing back to the United States, but will instead result in merely shifting trade to other countries, mostly in Asia. The associations instead propose the Congress focus its efforts on things that will help improve the competitiveness of the U.S. textile industry such as tax breaks and a trade policy that opens foreign markets to U.S. textiles. Furthermore, a restrictive yarn-forward U.S.-Central America FTA will only drive business away from Central America, eliminating the U.S. textile industry’s best customer.
AAFA President and CEO Kevin Burke submitted comments on October 31 in opposition to a petition that would remove Guatemala from the list of countries eligible to benefit from access to the U.S. market under various trade preference programs because of alleged labor rights problems. Burke noted the continual improvement in Guatemala’s labor rights situation, the existence of many factory certification and inspection efforts to supplement government enforcement activities, and the results of a recent International Labor Organization (ILO) report in his letter. A final decision on Guatemala is not expected until the middle of 2004. Posted November 12, 2003.
AAFA sent a letter on November 4 to every member of U.S. House of Representatives, urging passage of H.R. 1829, the Federal Prison Industries Competition in Contracting Act." H.R. 1829 would allow all government agencies to choose whether or not they want to buy products from Federal Prison Industries (FPI) or the private sector. FPI, which uses prison labor to manufacture apparel and many other items, currently has a "mandatory source" status that gives FPI the right of first refusal on U.S. government contracts. FPI's "mandatory source" status provides it with an unfair advantage over U.S. manufacturers. In the letter, AAFA also opposes any amendments to H.R. 1829, particularly those that would allow FPI to compete in the commercial marketplace. Posted November 4, 2003.
AAFA sent a letter on October 29 to all members of the House Appropriations Committee, urging them to retain Section 638 of the Senate Transportation-Treasury Appropriations bill during the legislations House-Senate conference negotiations. Section 638 allows all government agencies to choose whether or not they want to buy products from Federal Prison Industries (FPI) or the private sector. FPI currently has mandatory source status for all U.S. government agencies except the U.S. Defense Department, preventing U.S. apparel manufacturers from competing for many U.S. government contracts. Posted October 29, 2003.
AAFA and the American National Standards Institute (ANSI) Z41 Accredited Standards Committee for Performance Requirements for Protective Occupational Footwear (ANSI Z41) sent an October 1 letter to the Occupational Safety and Health Administration (OSHA) strongly opposing OSHA’s proposed slip resistance standards for occupational footwear. While agreeing that slips and falls are one of the greatest causes of industrial accidents in the United States, the letter expresses concern that the 0.5 Coefficient of Friction (COF) requirement proposed by OSHA does not reference either a particular test method, nor has any research to confirm that such a COF (depending on the test method) would have any beneficial results. A number of studies were conducted by members of ANSI Z41 and the American Society for Testing and Materials’ (ASTM F13) Committee on Pedestrian/Walkway Safety and Traction for Footwear. The result of these studies found that each of the four slip testers currently in use produces dramatically different COF results under the same exact conditions. Furthermore, there is no evidence that any of these slip meters accurately simulate actual human ambulation. Therefore, the letter urges OSHA to suspend its proposed rule and, instead, work with ANSI Z41, ASTM F13 and AAFA to develop a single standard test method that accurately reflects actual human ambulation. Posted October 28, 2003.
49 AAFA member company executives have sent a joint letter to the U.S. Trade Representative Ambassador Robert Zoellick asking for the swift negotiation and implementation of the U.S./Central America Free Trade Agreement (FTA). The October 16 letter pointed out that in order to be effective, the U.S./Central America FTA must enter into force by July 1, 2004, have a flexible rule of origin, provide immediate and reciprocal duty-free access for all textile, apparel and footwear products among U.S./Central America FTA countries, contain commonsense documentation procedures that reflect business practices, permit the continuation of duty-drawback mechanisms, establish secure "24/7" shipping environments and allow the Dominican Republic to integrate into the agreement as soon as possible. In a press release issued October 16, AAFA President & CEO Kevin M. Burke stated that, "AAFA believes that such a U.S./Central America FTA will allow US-based apparel and footwear companies to expand on already-successful partnerships in this hemisphere, as well as provide US-based supplier companies (including US knitters, weavers and yarn spinners) with a growing market for their products." Posted October 21, 2003.
On October 10, AAFA President and Chief Executive Officer Kevin M. Burke sent a letter to President George W. Bush urging him to end the punitive duties the U.S. currently imposed on a number of steel imports in 2002. As a result of those duties, the price of certain steel inputs used by U.S. apparel and footwear manufacturers have increased. U.S. footwear and apparel component manufacturers that also use steel inputs have also been rendered less competitive versus foreign components. The World Trade Organization (WTO) is expected to authorize the European Union in November 2003 to impose retaliatory tariffs of between 30 and 100 percent on a number of U.S. exports, including U.S.-made apparel and footwear. President Bush is expected to make a decision in the next few weeks whether he wants to end the steel duties. Posted October 21, 2003.
AAFA joined with more than 70 other association and corporate members of the Business Coalition for U.S. Central America Trade to urge the negotiation of a U.S./Central America Free Trade Agreement (FTA) that contains no exemptions for sectors, sub-sectors, or products. The October 15 letter sends a strong message to the U.S. and Central American negotiators that the FTA should be comprehensive so it creates meaningful market access for U.S. and Central American communities. Posted October 21, 2003.
AAFA joined with several other apparel import and retail trade associations on October 9 to propose a Textile Revitalization Act -- a series of measures designed to promote greater competitiveness for the textile industry to enable it to compete in a trade-based environment. The proposed Act, detailed in the letter, contains a number of short, medium and long-term initiatives -- some of which are already being debated within the Bush Administration and in Congress -- to foster a positive agenda to promote the growth and development of the U.S. textile industry. Posted October 21, 2003.
AAFA testified before the U.S. International Trade Commission (USITC) on October 7 and the Office of the United States Trade Representative (USTR) on October 8 regarding the upcoming negotiation of a free trade agreement between the U.S. and the Dominican Republic (U.S.-DRFTA). In the testimony, AAFA stated its support for a U.S.-DRFTA that is linked to a U.S.-Central America Free Trade Agreement (CAFTA). However, the testimony emphasized that in order for a U.S.-DRFTA and/or a CAFTA to be successful, they must include provisions such as: a flexible rule of origin; immediate duty free status for covered goods; continuation of the duty drawback program; simple and practical customs procedures; customs regulations that promote a "24/7" shipping environment; and transparent safeguard mechanisms, among others. Posted October 21, 2003.
AAFA marked the three-year anniversaries of the Caribbean Basin Trade Partnership Act (CBTPA) and the African Growth and Opportunity Act (AGOA) and the eleven-month anniversary of the Andean Trade Promotion & Drug Eradication Act (ATPDEA) by highlighting the fact all three trade preference programs still lack final Customs regulations. In an October 1 letter to Secretary of Homeland Security Tom Ridge, AAFA applauded passage of the three trade preference programs, noting that "These programs have not only benefited AAFA's members, but have greatly assisted in the economic development of the beneficiary countries." The letter states that the interim regulations issued by the U.S. Department of Homeland Security's Bureau of Customs and Border Protection (Customs) did not clearly address or left vague many specific issues that will hopefully be clarified in the final Customs regulations. Furthermore, without final regulations, U.S. apparel and footwear firms lack the regulatory certainty they need to fully take advantage of the benefits of each program. With three years already passed since implementation of two of these programs, AAFA asked that Customs issue final regulations for each program as soon as possible. Posted October 7, 2003.
On October 1, the House Small Business Committee held a hearing on Federal Prison Industries (FPI) and its impact on the small business community. Among the witnesses were members of the FPI Competition in Contracting Coalition, of which AAFA is an active member. Because of FPI's "mandatory source" status, it currently enjoys the right of first refusal on federal government contracts. FPI had over $600 million in sales last year, employing inmates at sub-minimum wage. Apparel is FPI's second largest manufacturing sector, followed only by furniture. AAFA's submitted comments that support a current legislative initiative, H.R. 1829, which would eliminate FPI's preferential status over the course of five years. AAFA also noted in its comments that it is opposed to any attempt by FPI to enter into the commercial marketplace. Posted October 7, 2003.
AAFA submitted written comments to the U.S. government on October 1 strongly supporting the proposed U.S.-Dominican Republic Free Trade Agreement (FTA). The comments note the immense benefits that would be derived from such an FTA for U. S. apparel, footwear and textile firms. According to AAFA, the FTA holds strong potential for increased employment in the U.S. textile and footwear supplier industries. Posted October 7, 2003.
AAFA and three other trade associations sent letters on September 8 to U.S. Senators Max Baucus (D-MT) and John McCain (R-AZ) and to U.S. Representatives Cal Dooley (R-CA) and Adam Smith (D-WA) expressing strong support for their bill, the Middle East Trade and Engagement Act of 2003. According to the letter, the legislation recognizes the importance of the apparel and textile industry as an important first step in industrialization for most developing countries. The bill offers duty-free access under flexible rules of origin for U.S. imports of apparel from Middle Eastern countries that qualify under the program. According to the letter, this preferential access will ensure that these countries will remain competitive after worldwide quotas are removed in 2005. The letter applauds the initiative as the first step towards a comprehensive free trade agreement with the region. The legislation would also grant duty-free access under flexible rules of origin for U.S. imports of footwear from the Middle East. Posted September 24, 2003.
AAFA sent a letter on September 8 to House Ways & Means Committee Chairman Bill Thomas (R-CA) expressing strong support of his bill to eliminate the Foreign Sales Corporation/Extraterritorial Income program. AAFA supports the bill because 1) the bill will eliminate the threat by the European Union (EU) to impose retaliatory duties on U.S. exports to the EU of U.S. made apparel, footwear and textiles and 2) will provide U.S. apparel and footwear manufacturers with much needed tax credits and investment incentives, particularly for small U.S. manufacturers. The bill will be considered this fall by the U.S. Congress. Posted September 17, 2003.
AAFA sent a letter on July 30 to the Office of the U.S. Trade Representative expressing its "very strong opposition to efforts to eliminate duty drawback under the U.S./Central America Free Trade Agreement (CAFTA) or other Free Trade Agreements (FTA)." Duty drawback and deferral programs rebate, defer or reduce duties paid on material inputs contingent upon exportation of the processed or finished goods. Many countries in Central America, the Caribbean, South America and Southern Africa as well as Morocco have extensive duty-drawback programs in place. The letter notes that duty drawback is necessary to ensure that the proposed FTAs are commercially-meaningful. Free trade zones and maquila operations, for which duty drawback usually applies, are critical in the development of infrastructure (ports, highways, power grids), sound customs compliance practices and community support systems, like schools, that are critical for a thriving sewn products industry in many of these countries. Posted August 6, 2003.
July 24, 2003 – Letter by Business Coalition for U.S./Central America Trade (of which AAFA is a member) in support of the negotiations for a Free Trade Agreement with the Dominican Republic.
July 23, 2003 – Letter by AAFA to President George W. Bush expressing opposition to the initiation of safeguards on U.S. imports from China.
July 22, 2003 – Letter by AAFA to selected Members of Congress supporting reform of Federal Prison Industries (FPI) as embodied in Competition in Contracting Act (H.R. 1829).
July 18, 2003 – Letter by AAFA to congressional leadership in support of U.S./Chile and U.S./Singapore Free Trade Agreement legislation.
July 16, 2003 – Joint communiqué issued by AAFA and 10 other associations in support of the U.S./Central America Free Trade Agreement (USCAFTA).
July 14, 2003 – Comments submitted by AAFA in connection with Federal Prison Industry regulations
On June 26, 66 Senators sent a letter to Senator Majority Leader Bill Frist (R - TN) to "express our support for quick Senate action on the Miscellaneous Trade and Technical Corrections Act of 2003 (S. 671)." According to the letter, "The United States Senate has an opportunity to pass a non-controversial bill that will provide crucial savings and an economic boost to U.S. manufacturers, consumers and workers." The Senate letter follows a May 12 letter sent by AAFA and more than 30 other companies and trade associations to Senator Charles Grassley, Chair of the Senate Finance Committee, urging swift passage of the legislation ( fact sheet, actual bill). The bill's over 350 non-controversial provisions include a provision to eliminate duties on virtually all U.S. imports of footwear (except 17 specific rubber/fabric and plastic/protective footwear items) under the Caribbean Basin Trade Partnership Act (CBTPA). Furthermore, the footwear would be able to enter duty-free even if made with imported uppers. A further provision clarifies that AGOA-eligible apparel can use a hybrid of U.S. and AGOA fabric. The bill also eliminates all duties on U.S. imports of certain synthetic filament yarn, certain rubber riding boots, certain yarn of combed cashmere, carded cashmere and camel hair and certain rayon filament yarn. The U.S. House of Representatives has already passed its version of the bill. Consideration by the full Senate, however, has stalled because Senator Richard Shelby (R - Alabama) wants to add a controversial provision that would remove duty-free benefits on socks assembled in Caribbean Basin countries under the CBTPA. Posted July 9, 2003.
June 20, 2003 – Letter by AAFA to Senate Armed Services Committee members regarding proposed changes to Berry Amendment in FY04 Defense Authorization Bill.
n June 18, AAFA President & Chief Executive Officer Kevin M. Burke testified before the Senate Foreign Relations Committee's East Asian & Pacific Affairs Subcommittee on the current situation in Burma (Testimony -- Press Release). During his testimony, Burke applauded the Senate's 97-1 vote on June 11, passing The Burmese Freedom and Democracy Act of 2003, and urged the House to pass the legislation as quickly as possible. The bill bans all imports from Burma until substantial progress has been made to curb human rights abuses in the country. Burke stated that AAFA strongly supports a total and immediate ban on U.S. imports from Burma because of the Burmese military regime's "...persistent and egregious violations of International Labor Organization (ILO) conventions on forced labor, child labor and the overall abhorrent labor (and human rights) situation in Burma." According to Burke, "Our association and its members realized that the only way to implement effective change at the factory level in Burma is to effectively change the government at the national level." AAFA, in announcing April 15 that the association and its members strongly support sanctions, became the first trade association to call for such a ban. Only one other association, the Travel Goods Association, the national association of the luggage and handbags industry, has since joined AAFA in calling for sanctions against Burma's military regime. Posted June 26, 2003.
AAFA sent a letter to U.S. Trade Representative Robert Zoellick and five Central American Trade Ministers demanding that the proposed U.S.-Central America Free Trade Agreement include commercially-meaningful, straightforward and flexible apparel and textile provisions in order to preserve existing commerce and effectively promote the expansion of regional partnerships, trade, investment and economic development. In the letter, AAFA urges that rules of origin for apparel and textiles under any agreement should be as simple and reasonable as possible, preferably resting on the widely accepted concept of substantial transformation. Duties on apparel should also be eliminated immediately upon implementation of the agreement in order to keep the region competitive, especially in light of the elimination of worldwide apparel quotas on January 1, 2005. If substantial transformation is not followed for apparel, AAFA advocates that the rules of origin, if based on a yarn-forward concept: allow for commercially meaningful and flexible Tariff Preference Levels (TPLs) to allow use of third country fabric and yarn; accumulation, which would allow use of yarn and fabric made in other countries that currently have a free trade agreement or trade preference arrangement with the United States (i.e. the Andean region, the Caribbean, Israel, Jordan, Mexico, etc.); and more workable short supply provisions. Finally, AAFA urges that the final free trade agreement incorporate streamlined and simplified customs procedures, including creating a 7-day a week, 24-hours a day (or 24/7) shipping environment so that Central America and the United States can fully take advantage of their proximity to each other. Posted June 24, 2003.
On May 29, AAFA sent letters to the U.S. Department of Transportation and the International Air Transport Association (IATA) opposing a proposal that would dramatically increase air freight costs for U.S. apparel and footwear firms. The proposal would change the volume to weight relationship from the present 6,000 cubic centimeters per paid kilogram to 5,000 cubic centimeters per paid kilogram. This change would result in an overall increase of approximately 20 percent. In the letter, AAFA argues that the proposal is effectively a substantial rate increase being adopted by IATA at a time when shippers in the United States and around the world are suffering from continued economic weakness in the world economy. The current 6,000 cc per paid kilogram conversion ratio has been in effect since 1981, and shippers have designed and constructed their production and packaging based upon the current standard. Apparel importers simply cannot refine their packaging any further to change the density of their cargo. The proposed IATA increase is unjustified, contrary to the public interest, and counter-productive to the economy's attempt to rebound from low consumer confidence and the recent SARS epidemic. Posted June 5, 2003.
AAFA submitted comments on Customs' interim regulations on the Caribbean Basin Trade Partnership Act (CBTPA), the Africa Growth and Opportunity Act (AGOA) and the Andean Trade Promotion & Drug Eradication Act (ATPDEA) on May 20 and May 27. Among other things, the comments call for a number of improvements to make the trade preference program more flexible and user friendly. CBTPA, AGOA and ATPDEA provided duty-free benefits for U.S. imports of all apparel (under certain restrictions) and virtually all footwear from the Caribbean and Central America, sub-Saharan Africa and the Andean countries of Bolivia, Columbia, Ecuador and Peru. Posted June 5, 2003.
AAFA sent a letter May 19 to the U.S. Trade Representative expressing concern regarding press reports that the initial U.S. market access offer on footwear in the ongoing Free Trade Area of the Americas (FTAA) negotiations does not reflect the unprecedented agreement reached between AAFA and the Rubber & Plastics Footwear Manufacturers Association (RPFMA). As stated in the February 21, 2003 letter from AAFA to U.S. Trade Representative Robert Zoellick, AAFA and RPFMA have agreed to allow all footwear items (except 17 specific rubber/fabric and plastic/protective footwear items) to go duty-free immediately in all future trade agreements. Furthermore, all footwear, except the 17 specific items, would receive reasonable rules of origin based on the simple substantial transformation standard. None of these non-17 items are domestically produced. The 17 exempted items, on the other hand, would be given the longest phase-out schedule offered in any agreement and would be subject to the more restrictive North American Free Trade Agreement (NAFTA) rules of origin. This agreement has already been enshrined in the U.S.-Chile Free Trade Agreement. The FTAA would be the world's largest free market, with a combined Gross Domestic Product (GDP) of nearly $13 trillion in 34 countries and nearly 800 million consumers stretching from Alaska to the tip of South America. Posted May 25, 2003.
May 12, 2003 – Letter by Business Coalition for U.S. Central America Trade, of which AAFA is a member, urging swift negotiation of a commercially meaningful USCAFTA.
May 12, 2003 – Letter by AAFA and more than 30 other associations and companies to Senate Finance Committee Chair Senator Charles Grassley (R-IA) urging approval of the Miscellaneous Trade and Technical Corrections Act of 2003.
April 25, 2003 – Letter by AAFA to Secretary Don Evans encouraging him to complete negotiations on a bilateral trade agreement with Vietnam.
AAFA announced April 15 that, due to the on-going cruel and repressive nature of the ruling regime in Burma, it has called for an immediate and total ban on U.S. textiles, apparel and footwear imports from Burma. In announcing AAFA's new policy, President and Chief Executive Officer Kevin M. Burke stated that, "The government of Burma continues to abuse its citizens through force and intimidation, and refuses to respect the basic human rights of its people. AAFA believes this unacceptable behavior should be met with condemnation from not only the international public community, but from private industry as well." On April 23, AAFA sent letters to Secretary of State Colin Powell, Secretary of the Treasury John Snow, Secretary of Commerce Donald Evans, Secretary of Labor Elaine Chao and U.S. Trade Representative Robert Zoellick requesting that the U.S. government immediately impose a complete ban on U.S. imports of apparel, footwear and textiles from Burma. Posted May 5, 2003.
In a March 27 letter to the Office of the U.S. Trade Representative (USTR), AAFA expressed strong support for the continued eligibility of the Andean countries of Bolivia, Colombia, Ecuador and Peru under the recently enacted Andean Trade Promotion & Drug Eradication Act (ATPDEA). The letter is in response to a USTR request for comments on whether all of the four countries continue to meet the eligibility requirements under ATPDEA. Posted April 3, 2003.
AAFA joined with other associations in expressing dismay with the initial offer made by the United States in the first round of negotiations for a U.S.-Vietnam Bilateral Textile Agreement which will place quotas on Vietnamese apparel. The March 10, 2003 letter strongly objects to the U.S. quota offer because the quota levels are based on U.S. imports from Vietnam before the lower tariff rates brought about by the December 2001 U.S.-Vietnam Bilateral Trade Agreement even went into effect. Furthermore, the U.S. offer includes quotas on products no longer even made in significant quantities in the United States, such as trousers and knit shirts. Finally, the import numbers show that apparel orders placed in Vietnam are not done at the expense of U.S. suppliers, but at the expense of other Asian suppliers. The letter ends by strongly urging the U.S. government to substantially revise its offer to reflect these realities as negotiations on a textile agreement continue in early April. Posted March 17, 2003.
In a February 18, 2003 letter, AAFA provided comments on the U.S. Customs Service's strawman proposals concerning proposed regulations for the mandatory collection by Customs of electronic cargo information prior to importation into or exportation from the United States. While AAFA strongly supports the continued efforts of Customs to ensure a safe and secure national cargo system, AAFA believes the lead times for electronic submission of manifest information proposed by Customs will lead to delays and could render the use of air transport worthless. Furthermore, the delays caused by the longer lead times will require cargo to sit for long periods in possibly unsecured areas, leading to the tampering that Customs is trying to prevent. Customs has posted the outline of the 8 proposals (one each for inbound and outbound for sea, air, truck and rail cargo) on its Web site. Posted March 5, 2003.
On February 21, 2003, AAFA sent letters to U.S. Representative Robert Zoellick and U.S. Secretary of Commerce Donald Evans outlining an unprecedented deal between AAFA and the Rubber and Plastics Footwear Manufacturers Association (RPFMA) that would allow all footwear, except 17 specific rubber/fabric and plastic/protective footwear items, to go duty-free in all future free trade agreements, including the proposed Turkey Qualified Industrial Zones (QIZ) program as well as the Free Trade Area of the Americas (FTAA) and the proposed free trade agreements with Central America, Southern Africa, Australia and Morocco. The letters outline the details of the agreement reached between the two associations and requests that the U.S. government work with the two associations ensure that this footwear agreement is accurately reflected in all future trade agreements. Posted February 21, 2003.
On January 31, 2003, AAFA and three other key trade associations representing the U.S. footwear industry sent letters to U.S. Trade Representative Robert Zoellick, U.S. Secretary of Commerce Donald Evans and the heads of 30 national footwear associations around the world telling them that the U.S. associations had agreed to advance sectoral negotiations in the footwear sector in the Doha Round of global trade negotiations. The letters propose that, except for 17 selected rubber/fabric and plastic/protective footwear items, all footwear duties in the United States should be eliminated on January 1, 2006. The letters also called for the reduction/elimination of all tariffs and non-tariff barriers on footwear worldwide, including all of the United States' major trading partners. Posted February 19, 2003.
At the conclusion of a successful first round of negotiations between the United States and five Central American countries (Costa Rica, El Salvador, Guatemala, Honduras and Nicaragua) towards a free trade agreement, AAFA and other organizations sent a letter to U.S. Trade Representative Robert B. Zoellick expressing support for the agreement. AAFA joined with the American Yarn Spinners Association and many AAFA members as part of the newly formed U.S. Hosiery Manufacturers Coalition in sending the Janaury 30, 2003 letter. The letter stresses the need that any U.S.-Central America Free Trade Agreement must grant immediate duty-free access to qualifying cotton and manmade fiber hosiery products from Central America so that the region stays competitive versus Asia. Posted February 19, 2003.
January 22, 2003 - President & CEO Kevin Burke testifies before Intenational Trade Commission on apparel industry post-2005.
Rachel Subler, Manager of Government Relations at AAFA, testified on January 7, 2003 at a public hearing held in Miami, FL before the Board of Directors of Federal Prison Industries (FPI). The Board called the hearing in order to learn about the impact of FPI on private businesses competing for government contracts. AAFA's testimony called on the Board to undertake a number of action items, including changes to the definitions of "market share" and "specific product." In addition to testimony by AAFA, many members of AAFA's Government Contracts Committee (GCC) were present and contributed to the question and answer period. FPI Board member Audrey Roberts thanked AAFA and its members for contributing to the education of the Board on the real impact that FPI has on the private apparel and textile sector. Janaury 17, 2003.
AAFA filed comments December 30, 2002 with the Federal Trade Commission (FTC) regarding the FTC's proposed policy statement describing the Commission's approach to self-reported minor and inadvertent violations of the labeling provisions of the Textile and Wool Acts. The FTC's proposal is not new, but rather is a formalization of its one-time leniency policy granted to companies for minor offenses that do not harm consumers, with the goal of encouraging companies to self-report. In its comments, AAFA commended the agency for such a reasonable position while expressing concern that, as written, the FTC policy may not accurately reflect the differences between large and small companies in terms of both production and organization, thus affecting the FTC's stated goal. Additionally, AAFA requested an opportunity for verbal dialogue and exchange of ideas with the FTC to further improve the applicability of the policy. Posted January 17, 2003.
AAFA compiled an extensive list of trade barriers to U.S. branded footwear and apparel products around the world in a letter to the U.S. government on December 13, 2002. AAFA’s list of trade barriers in Japan, Argentina, India, Mexico, Venezuela and elsewhere will be used as the government complied its 2003 National Trade Estimates report on foreign trade barriers. December 17, 2002.
AAFA strongly supports the creation of a U.S.-Central America Free Trade Agreement (CAFTA) that has common sense rules of origin and standardized customs procedures Senior Vice President Steve Lamar testified in a November 19, 2002 U.S. government hearing on CAFTA. Lamar’s testimony was echoed by Jerry Cook of AAFA member Sara Lee in his testimony on behalf of the Business Coalition for U.S.-Central America Trade, a new group formed specifically to support the creation of CAFTA. AAFA and many AAFA members have already joined the Coalition. Posted December 6, 2002.
AAFA believes that the U.S-Chile and the U.S.-Singapore Free Trade Agreements (FTAs) will have a minimal impact on U.S. employment in the U.S. apparel and footwear industries. In separate letters sent to the U.S. Trade Representative on November 19, 2002, AAFA noted that since neither Chile nor Singapore have significant apparel or footwear industries and because of the structure of the FTAs for apparel, U.S. imports will likely increase only slightly from each country. Furthermore, any increase would likely come at the expense of imports from other countries. Posted December 6, 2002.
AAFA believes that the U.S-Chile and the U.S.-Singapore Free Trade Agreements (FTAs) will have a minimal impact on U.S. employment in the U.S. apparel and footwear industries. In separate letters sent to the U.S. Trade Representative on November 19, 2002, AAFA noted that since neither Chile nor Singapore have significant apparel or footwear industries and because of the structure of the FTAs for apparel, U.S. imports will likely increase only slightly from each country. Furthermore, any increase would likely come at the expense of imports from other countries. Posted December 6, 2002.
AAFA joined with the U.S. Chamber of Commerce and several other trade associations to strongly urge both management and labor to resolve their remaining disputes in order to prevent another shutdown of West Coast ports. The November 12, 2002 letter urges the Pacific Maritime Association (PMA) and the International Longshore and Warehouse Union (ILWU) to take further advantage of the "cooling-off period" afforded to them since President George W. Bush Bush invoked the Taft-Hartley Act to continue negotiations. The "cooling-off period" ends on December 27, 2002. If the labor dispute is not resolved by that time, the West Coast ports may face another shutdown. With the assistance of a Federal mediator, the two sides have reached an agreement on the contentious issue of technology, but have not resolved some remaining issues concerning pensions. In the letter, the associations warn that U.S. industry and the U.S. economy will suffer further economic damage if no agreement is reached. The mediator announced November 6, 2002 that the sides will take a week break and return to negotiations around November 13, 2002. Posted November 8, 2002.
AAFA joined with several other trade associations in urging the U.S. government to promote clear, commonsense international guidelines that foreign countries can use to evaluate costs and benefits before they impose regulations. The November 5 letter to U.S. Trade Representative Robert Zoellick noted that, in recent years, there has been a proliferation of regulations by foreign governments that are not based on sound science nor are transparent, but which do act as a significant barrier to trade. Posted November 8, 2002.
AAFA President Kevin M. Burke sent a letter October 25, 2002 to the Secretaries of Commerce, State, Treasury, and Labor, the U.S. Trade Representative and the Chair of the International Trade Commission urging the development of clear, predictable and transparent guidelines to govern the operation of a safeguard provision affecting imports of textiles and apparel from China. Currently, no such guidelines exist, making it difficult to know how any petitions requesting relief under these provisions will be evaluated. Posted November 12, 2002.
AAFA sent a letter to CITA on October 11 strongly urging that CITA extend through the end of 2004 temporary amendments to the Special Access Program (SAP) and the Outward Processing Program (OPP) that allow certain non-U.S. formed, U.S. cut interlinings for tailored clothing to qualify under the 25 percent rule for non-U.S. findings and trimmings. Posted October 18, 2002.
AAFA joined with the National Retail Federation and the International Mass Retailers Association in sending comments September 16, 2002 to the U.S. Trade Representative (USTR) strongly supporting the inclusion of Bolivia, Colombia, Ecuador, and Peru as eligible for benefits under the newly-passed Andean Trade Promotion and Drug Eradication Act (ATPDEA). Most people believe that the USTR request on country eligibility is a pro-forma step and that all four countries are virtually assured of qualifying and receiving new benifits for footwear and apparel. Posted September 20, 2002.
AAFA submitted comments Sept. 9, 2002 opposing the U.S. Customs Service’s proposed rules requiring cargo declaration 24-hours before loading of U.S.-bound cargo at foreign ports. AAFA opposes the proposed rule because it does not follow the rational and all-inclusive procedures prescribed by Congress, increases security and theft risks by leaving cargo exposed in ports for longer periods, dramatically increases shipping time and delays, releases detailed, business confidential information to the general public (through manifests) and does not restrict use of the submitted information beyond security purposes. AAFA believes that if the Congressionally mandated procedures are followed, then Customs can develop a commonsense rule that increases border security without impeding the flow of trade. Posted September 20, 2002.
AAFA on Sept. 3, 2002 sent letters strongly opposing a proposal to create a new port security fee for importers to all members of Congress participating in the conference on pending port security legislation. AAFA opposes any new fee because U.S. footwear and apparel firms already pay huge tariffs and many fees while these same firms have already invested significant resources to improve border security. In addition, the proposal provides no guarantees that the revenue from the new fee will only be used for port security. Posted September 20, 2002.
AAFA joined with a dozen other organizations in a Sept. 5, 2002 letter strongly opposing the International Air Transport Association’s re, cent decision to change the weight relationship for air cargo. The letter, estimates that the , change in the weight relationship from 6,000 cubic centimeters per paid kilogram to 5,000 cubic centimeters per paid kilogram will increase shipping costs for importers an average of 20 percent. Posted September 20, 2002.
AAFA joined with seven other organizations in sending a letter on Aug. 29, 2002 to Andrew S. Natsios, Administrator for the U.S. Agency for International Development (AID), complaining about AID procurement practices. Specifically, the letter concerns USAID contracts soliciting bids for U.S. exports to third countries that prohibit these exports from containing components sourced from the People’s Republic of China because of China's classification as a "foreign policy-restricted country." After pointing out that Afghanistan, Cambodia and Vietnam are no longer on the list, the letter strongly urges AID to also remove China from the "foreign policy-restricted country" list. Furthermore, the letter states that the current restriction prevents U.S. manufacturers from successfully competing for AID contracts. Posted Aug. 30, 2002.
In response to a public request for comments and for testimony in a Sept. 9, 2002 hearing, AAFA sent a letter Aug. 21 to the U.S. Trade Representative strongly supporting a successful completion of the Free Trade Area of the Americas (FTAA). AAFA noted that negotiators must resolve a number of issues to have an effective FTAA, including protection of the Berry Amendment, liberalized and harmonized rules of origin, increased protections of intellectual property rights (IPR) for U.S. brands and improved and harmonized customs procedures. Posted Aug. 30, 2002.
AAFA, in an Aug. 19 letter to CITA, strongly endorsed an industry petition to designate 100 percent stock-dyed worsted wool woven fabric as in "short supply" in the United States under the Caribbean Basin Trade Partnership Act (CBTPA). If CITA approves the petition, apparel cut or sewn in Central America or the Caribbean from non-U.S. origin 100 percent stock-dyed worsted wool woven fabric is eligible for duty and quota-free entry to the United States under CBTPA. Posted Aug. 30, 20, 02.
AAFA supports the removal of U.S. duties on nonrubber footwear, socks and hosiery from the Caribbean Basin, certain filament yarn, cashmere, camel hair and textile covers but opposes U.S. duty-removal on certain straw hats and the exclusion of footwear and apparel from a proposed duty program for Turkey in its July 15, 2002 comments to the U.S. International Trade Commission and its July 19, 2002 comments to the Senate Finance Committee on the Miscellaneous Duty Bills currently before Congress. Posted July 19, 2002.
AAFA joined with over 60 other organizations to send a letter on July 10, 2002 to the House and Senate conferees on pending port security legislation. The organizations strongly oppose a provision in the legislation that would require that in-bond shipments be subject to a new, unique, and extremely detailed cargo description. Posted July 11, 2002.
AAFA submitted comments to the House Ways & Means Committee on July 8, 2002 on the proposed Department of Homeland Security. In particular, AAFA strongly endorsed the concept that the enforcement and trade facilitation mandates of the U.S. Customs Service must remain together and that Customs’ partnership with industry to ensure customs compliance be continued in any new Department. Posted July 11, 2002.
AAFA submitted comments to the U.S. Trade Representative (USTR) on July 2, 2002 on USTR's eigth annual review of the Andean Trade Preference Act (ATPA) program. AAFA argues that almost 90 percent of Andean imports are excluded from ATPA. Furthermore, AAAFA strongly supports the inclusion of apparel and nonrubber footwear in any renewal of ATPA because over 60 percent of the duties paid by ATPA countries are on those products and such inclusion will have no adverse impact on the United States. Posted July 11, 2002.
AAFA member Jerry Cook of Sara Lee Branded Apparel testified before the House Ways & Means Committee on June 26, 2002 regarding the concerns of the apparel and footwear industry over the inclusion of the U.S. Customs Service in the new Department of Homeland Security. Posted June 27, 2002.
AAFA on June 25, 2002 joined with the National Retail Federation, the International Mass Retail Association and the U.S. Association of Importers of Textiles and Apparel to strongly oppose a House Textile Caucus resolution. The letter, sent to members of Congress, urges them to not support the Textile Apparel and Recognition Act (TARA) because U.S. textile industry already receives the strongest protection of any U.S. manufacturing industry and, therefore, no more protections are needed or useful. Furthermore, many of the assertions in TARA are incorrect and would lead the Bush administration in the wrong direction on trade policy. Posted June 27, 2002.
AAFA submitted comments to the U.S. Trade Representative on June 14, 2002 on the U.S. negotiating strategy for the upcoming World Trade Organization Doha Trade Round. In the commen, ts, AAFA strongly supports the reduction/elimination of all U.S. and foreign tariffs on nonrubber footwear, apparel and textiles. Posted June 28, 2002.
AAFA submitted comments on June 7, 2002 on the U.S. House’s Miscellaneous Duty Bill, expressing strong support for miscellaneous duty bills eliminating tariffs on all U.S. imports of certain filament yarn, combed cashmere and camel hair as well as imports of nonrubber footwear, socks and hosiery from the Caribbean Basin. AAFA also noted that it does not support the removal of duties on U.S. imports of certain straw hats. Posted June 14, 2002.
AAFA submitted comments on June 6, 2002 on the U.S. International Trade Commission’s investigation into the effects of a possible U.S.-Taiwan Free Trade Agreement. AAFA believes a good agreement (with reasonable rules of origin) would have a beneficial effect on U.S. exporters of apparel and nonrubber footwear while also helping Taiwan prevent further erosion in its current market position as a major apparel and nonrubber footwear exporter to the U.S. Posted June 14, 2002.
In written comments on May 20, 2002 to the U.S. International Trade Commission (ITC) on ITC’s investigations into the effects of the reduction or elimination of U.S. or foreign tariffs, AAFA strongly supported the reduction of U.S. and foreign tariffs for textiles, apparel and nonrubber footwear. Posted June 14, 2002.
AAFA submitted comments May 9, 2002 to the International Trade Commission regarding its study on the possible effects of a proposed U.S.-Singapore Free Trade Agreement (FTA). In its comments, AAFA stated that trade in apparel and footwear is minimal between the two countries. Hence, the FTA will have little impact on these industries. AAFA, however, fully supports a well-constructed FTA that contains sensible, non-NAFTA rules of origin for both apparel and footwear. Posted May 17, 2002.
In response to a public request for comments, AAFA sent a letter May 1, 2002 to the Chair of the Free Trade Area of the Americas (FTAA) Secretariat strongly supporting a successful completion of the FTAA. AAFA noted that negotiators must resolve a number of issues to have an effective FTAA, including protection of the Berry Amendment, harmonized rules of origin, increased protections of intellectual property rights (IPR) for U.S. brands and improved customs procedures. Posted May 3, 2002.
AAFA sent a letter to the U.S. International Trade Commission (ITC) on April 29, 2002 on ITC's Investigation of U.S. Market Conditions for Certain Wool Articles. In the letter, AAFA stated that U.S. tailored clothing manufacturers are increasingly unable to find domestic sources of certain worsted wool fabrics and have been prevented by the U.S. Department of Commerce from receiving parity on tariffs on imported worsted wool with their Canadian counterparts. Posted April 30, 2002.
AAFA led a group of major U.S. trade associations in sending a letter on April 24, 2002 to every member of Congress strongly supporting swift Senate action to pass the Andean Trade Preference Act (ATPA). Posted May 3, 2002.
AAFA joined with a number of other associations in sending a letter to House Ways & Means Committee Chair Bill Thomas (R-CA) on April 16, 2002 strongly opposing any extension in the U.S. Customs Service's Merchandise Processing Fee (user fee) or application of fee proceeds to any non-Customs activity. Posted April 29, 2002.
AAFA joined with a number of other associations to send letters to House Majority Leader Richard Armey (, , R-, TX) and Homeland Security Director Tom Ridge on April 16, 2002. The letters requested that both officials work to ensure that the U.S. Customs Service is designated as the sole ag, ency to administer data collection and establish a security-oriented database regarding cargo containers as both houses of Congress consider bills on border security. Posted April 29, 2002.
AAFA submitted comments on April 5, 2002 to the U.S. Trade Representative on the proposed U.S.-Singapore Free Trade Agreement (FTA). In its comments, AAFA stated that trade in apparel and footwear is minimal between the two countries. Hence, the FTA will have little impact on these industries. AAFA, however, fully supports a well-constructed FTA that contains sensible, non-NAFTA rules of origin for both apparel and footwear. Specifically, the rules of origin should not include a yarn-forward rule for apparel nor should it include an unformed upper rule for footwear. Posted April 29, 2002.
AAFA sent a letter to the U.S. Customs Service on April 8, 2002 commenting on Customs' proposed regulations on imports of prototypes used solely for product development, testing, evaluation or quality control purposes. Posted April 9, 2002.
AAFA, the National Retail Federation, the Cltohing Manufacturer's Association and the Tailored Clothing Association sent a letter to Congressional staff on March 25 criticizing the U.S. Department of Commerce's handling of the worsted wool fabric provisions of the Trade and Development Act of 2000 and requesting Congressional assistance to ensure the fair and judicious implementation of those provisions. Posted April 9, 2002.
AAFA sent a letter to U.S. government negotiators March 28 strongly supporting the inclusion of a meaningful duty drawback program in the U.S.-Chile Free Trade Agreement (FTA). In the letter, AAFA argues that such a program would allow U.S. apparel firms to flexibly source components. AAFA also voiced its strong opposition to the possible inclusion of a yarn-forward rule in the FTA, stating that Chile’s minimal capacity to produce fabric or yarn and the prohibitive costs of shipping U.S. yarn and fabric to Chile would render the FTA useless for U.S. apparel firms. Posted Apr. 8, 2002.
AAFA, the U.S. Association of Importers of Textiles and Apparel (USA-ITA), the National Retail Federation (NRF) and the International Mass Retailers Association (IMRA) sent a letter to President George W. Bush on March 12 supporting the proposed U.S.-Central America Free Trade Agreement (FTA). Posted March 18, 2002.
AAFA submitted comments on Feb. 15 to the U.S. Trade Representative urging stronger enforcement of intellectual property rights worldwide to strengthen protection of U.S. apparel and footwear trademarks and brands. Posted Feb. 25, 2002.
On Feb. 7, AAFA submitted a statement to the House Ways and Means Committee regarding the 2002 Trade Agenda. Posted Mar. 13, 2002.
On Feb. 8, AAFA and more than a hundred other organizations and firms sent a letter to every member of the U.S. Senate urging the Senate to quickly pass Trade Promotion Authority (TPA) legislation. Posted Feb. 18, 2002.
AAFA's joint letter to Secretary of Commerce Donald Evans asking him to consider their views and include them in the deliberations of the new inter-governmental Textile Working Group. Posted Feb. 11, 2002.
Comments to U.S. Department of Commerce on Mexico’s continued limits on Mexican points of entry for imports of U.S. finished apparel, footwear and footwear parts. Posted Feb. 5, 2002.
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