Background

U.S. Customs and Border Protection saw a major rise in duties collected on textile goods in the second quarter of fiscal year 2020 as well as increases in some enforcement measures over the previous year. These trends are highlighted in statistics CBP recently made available on its efforts to enforce trade laws and regulations governing textiles.

For more information on trade-related issues affecting textiles and apparel, please contact trade attorney Elise Shibles at (415) 490-1403.

Textile and apparel goods have some of the highest import duty rates in the U.S. and may also be subject to Section 301 additional tariffs if imported from China. Schemes designed to circumvent these tariffs include illegal transshipment and origin fraud, invalid importers of record, inaccurate descriptions, undervaluation, smuggling and overstuffing, and de minimis use of trade preference programs and free trade agreements.

Textile and apparel goods are thus a top priority for CBP enforcement efforts. The chart below highlights trends in these efforts over the past year.

 

2Q 2020

2Q 2019

1Q 2020

Duties collected

$3.7 billion

$168.6 million

$2.2 billion

Factory visits

13

0

16

% factories discrepant

69

0

50

Non-IPR seizure number

187

135

183

Non-IPR seizure value

$1.6 million

$1.36 million

$2.0 million

IPR seizure number

1,745

978

1,441

IPR seizure value

$5.3 million

$2.69 million

$6.9 million

Commercial fraud penalties

3

1

0

Commercial fraud penalty value

$98,000

$38,000

0

Liquidated damages claims

79

252

42

Cargo examinations

2,862

3,376

3,571

% cargo shipments discrepant

6.5

5.75

7.28

Audits completed

21

9

10

Recommended/accepted audit recoveries

$13.1 million

$3.51 million

$10.7 million

Lab samples tested

120

141

184

% samples discrepant

45.8

39.7

48.9

Special enforcement operations initiated

4

6

2

Special enforcement operations completed

2

5

2

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