The American Apparel & Footwear Association (AAFA) has urged the Office of the United States Trade Representative (USTR) to address foreign trade barriers affecting US apparel, footwear and other sewn products companies, while calling for greater predictability in US tariff policy amid rising costs for the industry.
In its October 29, 2026, submission to USTR’s 2027 National Trade Estimate (NTE) Report on Foreign Trade Barriers, AAFA identified trade and regulatory concerns in Brazil, Canada, China, Colombia, El Salvador, Guatemala, Haiti, Honduras, India, Indonesia, Japan and Mexico. The comments, submitted by Audrey Clark, manager of trade and transportation at AAFA, were addressed to Mark DiPlacido, chair of the USTR Trade Policy Staff Committee.
AAFA has urged USTR to address trade barriers affecting US apparel, footwear and sewn-products companies across 12 markets, citing tariffs, customs delays, restrictive regulations and inconsistent enforcement.
It cited $28.44 billion in US tariffs in 2025 and called for predictable tariffs, lower input duties and improved trade facilitation.
Tariffs, quotas, technical standards, import licensing, customs procedures and local requirements increase costs, disrupt supply chains and restrict market access for US businesses, the association said in the report.
It also called on USTR to ensure that Industry Trade Advisory Committees have full membership and appropriate industry representation to strengthen private-sector participation in US trade policy.
AAFA highlighted the US industry’s exposure to international trade, saying about 97 per cent of clothes and shoes purchased in the country are imported, while roughly 95 per cent of consumers who buy these products live outside the US. Although much production takes place overseas, an estimated 70-75 per cent of the value of imported apparel comes from US-based activities such as design, marketing, compliance, logistics and retail. The association said footwear and travel goods were likely to have comparable contributions.
The submission also pointed to a sharp rise in US tariff costs. Citing Trade Partnership Worldwide, LLC data prepared for the association, AAFA said the average trade-weighted tariff rate on apparel imports increased from 14.70 per cent in 2024 to 24.56 per cent in 2025. The rate for footwear rose from 12.26 per cent to 23.75 per cent, while that for travel goods increased from 13.85 per cent to 22.83 per cent.
Total tariffs collected on US imports of apparel, footwear and travel goods reached approximately $28.44 billion in 2025, up 68 per cent from $16.89 billion in 2024. The industry paid a further $17.90 billion in tariffs through August 2026, including around $8.23 billion in additional duties imposed under presidential trade authorities, according to AAFA.
The association raised concerns about uncertainty surrounding US tariffs imposed under Sections 301, 232, 122 and 338, saying overlapping and changing duties complicate sourcing decisions, long-term planning and supply-chain operations. It called for a non-stacking approach to prevent multiple tariffs applying to the same products, the removal of duties on manufacturing inputs and machinery, and exemptions from additional tariffs for goods qualifying under free trade agreements (FTAs). It also sought adequate lead times for new measures so businesses, supply chains and enforcement agencies can understand requirements, update systems and implement changes.
AAFA said tariffs on imports containing substantial American value, including intellectual property and domestically sourced materials, raise costs for US companies and consumers. With limited domestic alternatives for some goods, it argued, additional duties on essential consumer products place a further burden on businesses and families.
Country-specific trade concerns
In India, AAFA said Bureau of Indian Standards (BIS) Quality Control Orders require factory-by-factory certification, testing and audits, as well as BIS marking on each pair of footwear. It cited certification backlogs and alleged that domestic footwear manufacturers were not subject to equivalent requirements. The association said the rules were increasing costs and making it difficult for US companies to serve the Indian market, forcing some to leave.
In China, AAFA flagged inconsistent customs procedures, additional certificate-of-origin information requirements, unofficial reference price lists and a lack of transparency in regulations. It said customs practices could vary between ports and officials, while requirements differed across provinces. The submission also raised concerns about restrictions on recycled materials used in textile production and alleged retaliatory measures against US companies complying with American forced-labour laws.
In Mexico, the association said estimated-pricing requirements remained applicable to footwear even after similar measures for textiles and apparel were removed in September 2026. Importers whose declared transaction values fall below reference prices must provide financial guarantees, potentially tying up capital for 12 months or longer if an investigation is initiated. AAFA also cited additional tariffs, customs documentation and reporting requirements, and rules requiring clothing sizes to be displayed in Spanish before other languages.
Other concerns included Colombia’s customs valuation thresholds for textile, apparel and footwear imports; Indonesia’s expanded halal certification requirements for certain clothing, footwear, leather goods and accessories containing animal-derived materials; and Japan’s high tariff-rate quota on leather footwear.
In Canada, AAFA members reported concerns about customs audits, tariff classification rulings and proposed changes to customs valuation rules. In El Salvador, the association cited documentation requirements, customs enforcement issues and procedures affecting goods moving through free trade zones. It also called for greater harmonisation of customs procedures across El Salvador, Guatemala and Honduras.
In Haiti, gang violence and political instability were said to have disrupted the movement of raw materials and finished goods, contributed to factory closures and discouraged investment. AAFA welcomed the extension of the HOPE/HELP trade preference programmes through December 31, 2028, while calling for continued efforts to restore security and reliable transport networks.
Regulatory, digital and transport issues
Beyond country-specific concerns, AAFA called for greater international harmonisation of chemical management, product safety and labelling rules. It said differences in national requirements increase compliance costs and delays for companies operating across markets. Its submission also identified concerns involving the US Customs and Border Protection (CBP) 9802 programme, the Western Hemisphere Incentive Program, customs enforcement consistency and communication, intellectual property protection and trade preference programmes.
The association urged support for digital labelling, saying it could reduce material waste, improve access to product information and make it easier to update details as regulations change. It estimated that apparel companies produce about 5.7 million miles of label tape annually, generating at least 343,000 metric tonnes of carbon dioxide equivalent emissions. AAFA said digital labels could also support product recycling and improve accessibility for visually impaired consumers.
The submission raised concerns about data localisation requirements and restrictions on cross-border data flows, as well as shipping disruptions caused by Red Sea attacks and port labour strikes. On maritime and shipbuilding fees under Section 301, AAFA welcomed USTR’s proposal to extend their suspension through January 9, 2027, but called for the measures to be permanently withdrawn to provide greater certainty for importers.
AAFA also urged the US administration to promote implementation of the World Trade Organization’s Trade Facilitation Agreement to speed up the movement of goods and improve co-operation between customs authorities. It called for renewal of the Generalized System of Preferences, which expired on December 31, 2020, and supported longer-term extensions and reforms to the African Growth and Opportunity Act and Haiti’s HOPE/HELP programmes.
The association urged USTR to work with other federal agencies and industry representatives to address the barriers identified in its submission.
Fibre2Fashion News Desk (CG)
