The American Apparel & Footwear Association (AAFA) recently submitted comments opposing US Customs and Border Protection’s (CBP) proposed reclassification of women’s shirts. In a letter, AAFA president and chief executive officer Rick Helfenbein said CBP’s proposed modification overturn decades of precedent and industry best practice, and create tremendous confusion.
“While we specifically object to what CBP is trying to do with this specific ruling change, the far-reaching nature of this proposal raises additional troubling process questions about whether a notice in the Customs Bulletin is sufficient. Second, while CBP is technically correct that there is no specific requirement in the HTSUS [Harmonised Tariff Schedule of the United State] for a means of closure for a garment with a partial opening to be classified in HTS Heading 6106, CBP itself was responsible for establishing a means of closure requirement as the de facto standard through decades of precedent, going back to at least 1996,” the letter said.The American Apparel & Footwear Association recently submitted comments opposing US Customs and Border Protection's proposed reclassification of women's shirts. In a letter, AAFA president and chief executive officer Rick Helfenbein said CBP's proposed modification overturn decades of precedent and industry best practice, and create tremendous confusion.#
Further, this change would have a huge tariff impact on what is one of the largest apparel categories on the market, women’s cotton tops. Already, these tops are subject to 31.5 per cent tariff.
CBP’s proposed reclassification would only add insult to injury, driving up the total tax bill on these cotton tops to a whopping 34.7 per cent, the letter added.
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