U.S. Customs and Border Protection saw increases in some measures of its efforts to enforce trade laws and regulations governing textiles in fiscal year 2023, including particularly large increases in liquidated damages claims, commercial fraud penalties, and cargo exams. However, CBP also saw decreases in Section 301 tariffs collected, seizures, and audits.
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 charts below highlight trends in these efforts over the previous quarter and the past year.
|
|
4Q 2023
|
3Q 2023
|
4Q 2022
|
|
Section 301 duties collected
|
$697 million
|
$624 million
|
$953 million
|
|
Forced labor e-allegations
|
6
|
9
|
n/a
|
|
Factory visits
|
33
|
24
|
25
|
|
% factories discrepant
|
24
|
40
|
64
|
|
Non-IPR seizure number
|
174
|
149
|
379
|
|
Non-IPR seizure value
|
$3.7 million
|
$5.9 million
|
$6.99 million
|
|
IPR seizure number
|
1,116
|
1,134
|
1,072
|
|
IPR seizure value
|
$33.3 million
|
$36.8 million
|
$13.6 million
|
|
Commercial fraud penalties
|
2
|
1
|
3
|
|
Commercial fraud penalty value
|
$526,000
|
$286,000
|
$1.2 million
|
|
Liquidated damages claims
|
791
|
506
|
56
|
|
Cargo examinations
|
8,652
|
9,404
|
4,409
|
|
% cargo shipments discrepant
|
6.21
|
6.03
|
7.6
|
|
Audits completed
|
8
|
4
|
8
|
|
Recommended/accepted audit recoveries
|
0
|
0
|
$8.4 million
|
|
Lab samples tested
|
103
|
85
|
94
|
|
% samples discrepant
|
44
|
32
|
28
|
|
Special enforcement operations initiated
|
9
|
13
|
3
|
|
Special enforcement operations completed
|
18
|
13
|
4
|
|
|
2023
|
2022
|
|
Section 301 duties collected
|
$2.55 billion
|
$3.6 billion
|
|
Forced labor e-allegations
|
30
|
n/a
|
|
Factory visits
|
57
|
5
|
|
% factories discrepant
|
21
|
53
|
|
Non-IPR seizure number
|
716
|
1,190
|
|
Non-IPR seizure value
|
$20.3 million
|
$23.2 million
|
|
IPR seizure number
|
4,300
|
4,758
|
|
IPR seizure value
|
$108.8 million
|
$76.1 million
|
|
Commercial fraud penalties
|
19
|
9
|
|
Commercial fraud penalty value
|
$19.3 million
|
$2.45 million
|
|
Liquidated damages claims
|
1,840
|
288
|
|
Cargo examinations
|
27,886
|
16,177
|
|
% cargo shipments discrepant
|
6.52
|
17.1
|
|
Audits completed
|
19
|
27
|
|
Recommended/accepted audit recoveries
|
$2.16 million
|
$13.6 million
|
|
Lab samples tested
|
323
|
451
|
|
% samples discrepant
|
42
|
48
|
|
Special enforcement operations initiated
|
56
|
4
|
|
Special enforcement operations completed
|
50
|
5
|
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