Background

U.S. Customs and Border Protection saw increases in some measures of its efforts to enforce trade laws and regulations governing textiles in the fourth quarter of fiscal year 2021, including Section 301 tariffs collected and audits completed, but decreases in others, including factory visits and liquidated damages claims.

For more information on trade-related issues affecting textiles and apparel, please contact textile and apparel practice leader Elise Shibles at (415) 490-1403 or via email.

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 previous quarter and the past year.

 

4Q 2021

3Q 2021

4Q 2020

Section 301 duties collected

$948 million

$701 million

$851 million

Factory visits

0

13

0

% factories discrepant

n/a

85

n/a

Non-IPR seizure number

106

114

120

Non-IPR seizure value

$1.2 million

$2.1 million

$490,000

IPR seizure number

1,125

1,116

1,231

IPR seizure value

$21.7 million

$10.2 million

$12.2 million

Commercial fraud penalties

0

2

0

Commercial fraud penalty value

0

$923,000

0

Liquidated damages claims

93

146

104

Cargo examinations

2,507

3,946

2,672

% cargo shipments discrepant

5.27

7.35

5.13

Audits completed

13

12

10

Recommended/accepted audit recoveries

$100 million

$400,000

$4.2 million

Lab samples tested

153

178

109

% samples discrepant

48.0

59.0

45.0

Special enforcement operations initiated

1

3

2

Special enforcement operations completed

4

1

4

 

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