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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