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 second quarter of fiscal year 2022, including seizures, liquidated damages claims, and cargo examinations, but decreases in others, including Section 301 tariffs collected and fraud penalties.

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.

 

2Q 2022

1Q 2022

2Q 2021

Section 301 duties collected

$902 million

$937 million

$690 million

Factory visits

0

0

0

% factories discrepant

n/a

n/a

n/a

Non-IPR seizure number

171

155

122

Non-IPR seizure value

$2.9 million

$3.6 million

$3.9 million

IPR seizure number

1,422

1,007

1,369

IPR seizure value

$34 million

$12.7 million

$7.7 million

Commercial fraud penalties

0

3

2

Commercial fraud penalty value

0

$918,000

$158,000

Liquidated damages claims

105

27

253

Cargo examinations

5,075

2,808

3,576

% cargo shipments discrepant

39.5

6.4

5.6

Audits completed

12

5

10

Recommended/accepted audit recoveries

$2.54 million

$1.8 million

$5.7 million

Lab samples tested

136

135

171

% samples discrepant

65.0

45.0

47.0

Special enforcement operations initiated

0

5

6

Special enforcement operations completed

0

4

4

 

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