Textile Enforcement Efforts See Mixed Results in Third Quarter

U.S. Customs and Border Protection saw increases in some measures of its efforts to enforce trade laws and regulations governing textiles in the third quarter of 2021, including factory visits, cargo exams, and audits, but decreases in others, including seizures and liquidated damages claims.

For more information on trade-related issues affecting textiles and apparel, please contact attorney 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.

	3Q 2021	2Q 2021	3Q 2020
Section 301 duties collected	$701 million	$697 million	$536 million
Factory visits	13	0	0
% factories discrepant	85	n/a	n/a
Non-IPR seizure number	114	124	53
Non-IPR seizure value	$2.1 million	$4 million	$1 million
IPR seizure number	1,116	1,368	645
IPR seizure value	$10.2 million	$7.7 million	$4.9 million
Commercial fraud penalties	2	2	3
Commercial fraud penalty value	$923,000	$158,000	$489,000
Liquidated damages claims	146	254	59
Cargo examinations	3,946	3,608	2,532
% cargo shipments discrepant	7.35	5.74	4.75
Audits completed	12	10	7
Recommended/accepted audit recoveries	$400,000	$5.7 million	0
Lab samples tested	178	171	72
% samples discrepant	59.0	47.0	43.0
Special enforcement operations initiated	3	6	1
Special enforcement operations completed	1	4	0

 

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