Nate Herman, executive vice president at the American Apparel & Footwear Association (AAFA), recently testified at the office of the USTR on behalf of the FLWG opposing such tariffs.
The US Forced Labor Working Group has urged the USTR not to impose Section 301 tariffs, as these would be counterproductive, legally unwarranted, and harmful to commerce.
If this probe leads to tariff actions, good actors that have invested in forced-labor compliance would face higher costs, with no benefit, while bad actors would gain by sourcing from lower-cost alternatives in regions with less oversight
FLWG, set up in 2019, represents thousands of members and tens of millions of American workers across chemicals, apparel and footwear, motor vehicles, consumer electronics, agriculture, clean energy, jewellery, retail, and international trade industries with global supply chains.
Tariffs are a tax on US importers, not foreign producers—they would raise costs, disrupt supply chains, and harm US businesses, workers and consumers, Herman said.
If this investigation leads to tariff actions, it would do nothing to address forced labour. Instead, good actors that have already invested heavily in forced-labour compliance would face increased compliance costs, with no benefit, while bad actors would benefit by sourcing from lower-cost alternatives in regions with less oversight, FLWG noted.
Therefore, the group urged USTR to consider actions that would make a significant difference in eradicating forced labour.
It urged the US government to assist the subject economies with the development of enforcement programmes, including sharing methodologies, technologies and investigative approaches.
Further, the US government should restore funding to the International Labour Organization, the International Organization for Migration, the US Department of Labor’s Bureau of International Labor Affairs, and the State Department’s Bureau of Democracy, Human Rights and Labor.
These organisations provide essential infrastructure for building partner-country enforcement capacity on forced labour, mentioned Herman.
If the USTR moves forward in its investigation, as required by the statute, it should publish a preliminary report with findings, proposed scope and economic modeling before finalising recommendations, followed by a second comment period, he noted.
And, if tariffs are ultimately imposed, they must be narrowly targeted to specific products or producers with documented evidence, limited in duration with sunset provisions, implemented with at least one year of advance notice, include the tariff relief that already exists under the Section 122 tariffs, and not be stacked on top of other tariffs, he added.
Fibre2Fashion News Desk (DS)
