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.
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. http://usindustrialbabrics.ifai.com/
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. http://narrowfabrics.ifai.com/
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
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.
Click here to view the complete technical textiles events calendar that includes show information links.
Despite the increasingly complex industry demands, the Chinese technical textiles market was relatively stable. Nonwovens output increased over last year. Key specific markets such as tire cord also increased in 2018 over 2017. Overall operating income for industrial textiles used in China reached $34 billion. Click here to read the complete summary provided to BeaverLake6 Report by China Textile magazine through our exclusive relationship. Posted February 15, 2019
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.
IFAI Expo 2018 was the first show under IFAI's new CEO/President Steve Schiffman. In a quick conversation on the first day, Mr. Schiffman thought event attendance was on target with the expectation of a 500 increase over the 4500 total participants (counting both exhibitors and visitors) they had in 2017 in New Orleans. Similarly, a conversation with one of the managers of ACMA, a partner in CAMX, said their pre-registration had already topped the 6500 they had last year in Orlando. (Keep in mind, though, the 2017 CAMX show had to be rescheduled from September to December because of Hurricane Irma.) Click here to read more about the shows. Posted October 19, 2018
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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 continue.]
Posted November 21, 2018
NAFTA Replacement Agreement Negotiated. On October 1, President Donald Trump announced the US, Mexico and Canada had reached an agreement whichreplaces the North American Free Trade Agreement (NAFTA) that went into effect in 1994. The new United States-Mexico-Canada Agreement (USMCA) contains provisions and language that has an impact on the technical textiles industry; the most important are 1) a special section covering textiles and apparel and 2) rules of origin that will require 75% of automotive content (under NAFTA 62.5%) be made in North America. Mexico and Canada are the two largest importers of US made technical textiles and the automotive industry is the largest intended end market of these technical textiles. Click here to go to the United States Trade Representative's website and read the "Textiles and Apparel Goods" chapter. Posted October 3, 2018
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. Posted June 18, 2018
I am pleased to announce the second part of my report 2018 State of the U.S.Technical Textiles Industry has been published by Textile World magazine.
This first part features a general industry overview, plus an evaluation of the status and impact of US trade positions.
The second part, featured in the April/May issue will cover major end markets for technical textiles such as automotive and military.
Click here to go to the Textile World website to download a copy.
Steve Warner, Publisher
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