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North American Free Trade Agreement Renegotiating Public Comments 

The United States Industrial Fabrics Institute (USIFI) and the Narrow Fabrics Institute (NFI), both divisions of the Industrial Fabrics Association International IFAI) have submitted their comments regarding US President Donald Trump's intent to open the North American Free Trade Agreement for modernization in today's marketplace. Other trade associations -- including the National Council of Textile Organizations -- and industry companies have also submitted the public comments regarding NAFTA.


The following is the USIFI/NFI public comment filed on June 12 with the US Trade Representatives Office.  

Public Comments of the U.S. Textile Industry Regarding Docket USTR–2017–0006, Negotiating Objectives Regarding Modernization of North American Free Trade Agreement with Canada and Mexico (NAFTA Negotiations)

June 12, 2017


These comments are provided on behalf of the United States Industrial Fabrics Institute (USIFI) and Narrow Fabrics Institute (NFI) in response to the Federal Register request for public comments found at 82 FR 23699 and dated May 23, 2017 (USTR–2017–0006).


The United States Industrial Fabrics Institute (USIFI) is a division of the Industrial Fabrics

Association International (IFAI). Member companies manufacture highly-specialized textile

products, advanced materials, and components used to support a variety of high-value-added and sophisticated industries. These include the aerospace, automotive, construction, marine, medical, military and safety/protective gear sectors among others. USIFI currently has 75 member companies, and its headquarters are in Roseville, MN. 


The Narrow Fabrics Institute (NFI) is a division of the Industrial Fabrics Association International (IFAI) whose mission is to work on common interests and issues in the narrow fabrics industry. Narrow fabrics are defined as textiles that are no more than 12 inches (300mm) in width and are made by weaving, knitting or braiding fibers or yarns with an edge to prevent unraveling. The primary product areas of NFI’s 57 member companies include automotive, military, safety, transportation, medical, and other (aerospace, industrial, pet, recreational, electronics). The North America market is estimated at over $335 million in annual sales.


USIFI and NFI agree that NAFTA is due for comprehensive review to determine whether it can be improved. However, noting that U.S. textile and apparel exports to NAFTA totaled $11.1 billion in 2016 and the high level of integration that exists today in the North American textile supply chain, USIFI and NFI oppose a wholesale cancelation of NAFTA.


Instead, USIFI and NFI support an improvement along the lines of:


Committing greater resources and focus to customs enforcement

During the past 30 years, there has been a systematic deemphasis of commercial fraud

enforcement at U.S. Customs and Border Protection (CBP). CBP suffers from both a lack of resources and focus, especially noting the uptick in the number of trade agreements and

overall trade flows during this timeframe. Consequently, the benefits of these agreements

have been siphoned off by third-party countries and importers willing and able to

circumvent U.S. trade laws and agreements.


USIFI and NFI strongly support the adoption of a new mentality that places an increased,

but proper, emphasis on customs enforcement of NAFTA and other FTAs. We encourage

the Trump administration and Congress to tangibly demonstrate that new approach by

increasing resources at CBP to enable more effective enforcement of U.S. trade laws and

duty assessments.


USIFI and NFI also note that more effective trade enforcement will not only pay for itself,

but also generate new revenues that could then be used to promote trade facilitation

through the rebuilding and expansion of America’s infrastructure.


Eliminating exceptions to yarn forward in the NAFTA rule of origin

The standard rule of origin for textiles in nearly all U.S. FTAs is the yarn-forward rule, which requires yarn and everything following the yarn stage to be done in the FTA region. Yarn forward was originally devised under NAFTA and is the accepted rule of origin for the domestic textile industry because it reserves key benefits for manufacturers within the signatory countries. A yarn-forward concept is also markedly easier to enforce versus a value-added rule of origin.


Although most U.S. FTAs are built on yarn forward as the basic structure, exceptions to the basic rule exist in many agreements that shift business away from U.S. producers to FTA parties, namely China. These yarn-forward loopholes take many forms, with the most egregious being TPLs. TPLs allow for a specific quantity products to be shipped duty free among free trade partner countries even though the components within the product are sourced from countries that are not signatories to the agreement.


Under NAFTA, Mexico is permitted ship up to the equivalent of 24 million square meters (SME) of certain fabrics and made-up textile articles, including man-made fiber industrial products, annually to the U.S. duty free. Canada has a 72 million SME TPL for this category of articles. There are three additional TPLs for cotton and man-made fiber yarns, cotton and man-made fiber apparel, and wool apparel. These and other loopholes and should be eliminated in any renegotiation.


Closing the loophole that dilutes the Kissell Amendment

The Kissell Amendment, 6 USC 453b, is a Berry Amendment-like buy American law for textiles that applies to the Department of Homeland Security (DHS). In practice, however, DHS only applies Kissell to purchases by the Coast Guard and Transportation Security Administration (TSA) because of U.S. commitments made under the WTO’s Revised Agreement on Government Procurement (GPA).


With respect to its application to TSA, Kissell has further been diluted. This is because the U.S. government failed to notify Mexico and Canada under NAFTA, as well as Chile under the Chilean FTA, that the United States was reserving TSA from the GPA when TSA was created. Thus, the United States has taken the position that those countries are acceptable as U.S. sources under Kissell. This oversight should be rectified in any NAFTA renegotiation.


Thank you for your consideration of our views, and we look forward to working with the Trump administration in the NAFTA modernization effort.

Coming Events

  • November 11-14:  Hygienix, Houston, Texas, USA
  • November 13-15:  JEC Asia 2019, Seoul, South Korea
  • November 18-19:  EurAsian Geosynthetics Symposium 2019, Beijin, China
  • November 18-21:  Defense & Security 2019, Bangkok, Thailand
  • November 19-21:  Absorbent Hygiene Training Course, Cary, N.C., USA
  • November 19-21:  Milipol Paris 2019, Paris, France
  • November 20-22:  Techtextil India 2019, Mumbai, India

Click here to view the complete technical textiles events calendar that includes show information links.

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In 2018, China's industrial textile industry maintained a relatively rapid growth. The year, though, also found more complex challenges for the industry, including the tariff issues with the US. Thanks to BeaverLake6 Reports' exclusive arrangement with China Textile magazine, we are presenting the English-translated version of the final 2018 report written by the China Nonwovens & Industrial Textile Association (CNITA).  The report included information on fiber and material production, plus selected large end-product markets. Click here to read the report. Posted September 3, 2019

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[Read the rest of my editorial that takes NCTO to task for its hypocritical "moral" argument supporting the proposed additional products but excluding its industry's suppliers by clicking here.]


Steve Warner


Posted June 17, 2019

China's Industrial Textile Market Demands Still Remains Vigorous

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Does IDEA Show Need to be in Miami Beach?

INDA, the Association of the Nonwovens Fabrics Industry, has issued its final report on IDEA19.  The event held March 25-27, 2019 in Miami Beach, Fla., USA, attracted 6,500+ participants and 509 exhibiting companies from 75 countries.  Show floor space was a record 168,600 square feet, a 9% increase over the previous show. 


Surprisingly, the people and exhibitor participation figures are not record numbers. The IDEA16 show in Boston, Mass., USA, attracted 7000+ and 555 exhibitors. 


So, why was participation down this year from IDEA16?  I think an explanation for the decline is the South Florida location of IDEA19.  Click here to read more.

President Li Lingshen, President, China Nonwovens & Industrial Texiles Association

President Li Lingshen

BeaverLake6 Report is pleased to provide an exclusive interview with Li Lingshen, Ph.D., Vice President of the China National Textile and Apparel Council, and President of the China Nonwovens & Industrial Textiles Association, the overseeing organization for the technical textiles industry in China. Click here to read the interview.

NCTO Neglects Automotive Textiles as Organizations Testify          on Proposed USMCA Impact

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The two organizations clearly have different biases; however, in looking over the AAFA and NCTO statements, it appears to me that while the organizations both clearly said they were not offering an endorsement yet of the agreement, they gave general overall approval for USMCA, acknowledging the 1992 North American Free Trade Agreement (NAFTA) needed updating. Both organizations are taking a wait-and-see attitude to more fully look at how the agreement impacts the complex supply chain of textiles and apparel. Click here to read more.

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State of the Chinese Technical Textiles Markets in 2017

Are you looking for a quick understanding of the China technical textiles industry? Through our special relationship with China Nonwovens & Industrial Textiles Association (CNITA) and their China Textile publication, BeaverLake6 Report is pleased to post the English-translation of the recently issued "Status Quo of China's Nonwovens and Industrial Textiles Industry, 2017." The report covers the different levels of the industry, geographic export demographics, and forecast the needs in the major end market applications. Click here to read the report in our China Textile website section. 

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