Background

U.S. Customs and Border Protection saw an increase in many measures of its efforts to enforce trade laws and regulations governing textiles in the fourth quarter of 2020, according to recently-released statistics.

For more information on trade-related issues affecting textiles and apparel, please contact 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 false invoicing, false marking and labeling, false claims of origin, illegal transshipment, misdescription, undervaluation, false declarations of the right to make entry, false trade preference claims, and smuggling.

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.

 

 

4Q 2020

3Q 2020

4Q 2019

Section 301 duties collected

$851 million

$536 million

$857 million

Factory visits

0

0

58

% factories discrepant

n/a

n/a

26

Non-IPR seizure number

120

53

205

Non-IPR seizure value

$490,000

$1 million

$2.94 million

IPR seizure number

1,231

645

1,143

IPR seizure value

$12.2 million

$4.9 million

$5.81 million

Commercial fraud penalties

0

3

4

Commercial fraud penalty value

0

$489,000

$100,000

Liquidated damages claims

104

59

64

Cargo examinations

2,672

2,532

3,316

% cargo shipments discrepant

5.13

4.75

7.84

Audits completed

10

7

15

Recommended/accepted audit recoveries

$4.2 million

0

$2.2 million

Lab samples tested

109

72

186

% samples discrepant

45.0

43.0

52.1

Special enforcement operations initiated

2

1

0

Special enforcement operations completed

4

0

0

 

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