The American Apparel & Footwear Association (AAFA) has formally urged the Office of the United States Trade Representative (USTR) to address a wide range of foreign trade barriers affecting US apparel, footwear, and sewn products companies. The call came alongside a demand for greater predictability in US tariff policy, as costs across the industry continue to climb sharply.
The submission, dated October 29, 2026, was filed in response to USTR’s 2027 National Trade Estimate (NTE) Report on Foreign Trade Barriers. It was submitted by Audrey Clark, manager of trade and transportation at AAFA, and addressed to Mark DiPlacido, chair of the USTR Trade Policy Staff Committee.
Scope of AAFA Trade Barriers Concerns
In its USTR NTE report submission, AAFA identified trade and regulatory concerns spanning twelve countries: Brazil, Canada, China, Colombia, El Salvador, Guatemala, Haiti, Honduras, India, Indonesia, Japan, and Mexico. The association noted that tariffs, quotas, technical standards, import licensing, customs procedures, and local requirements are collectively increasing costs, disrupting supply chains, and restricting market access for US businesses.
AAFA also called on USTR to ensure that Industry Trade Advisory Committees maintain full membership and appropriate industry representation, with the goal of strengthening private-sector participation in the formulation of US trade policy.
The Industry’s Deep Dependence on Global Trade
AAFA highlighted the significant degree to which the US apparel and footwear industry is tied to international trade. Approximately 97 per cent of clothes and shoes purchased in the United States are imported, while roughly 95 per cent of consumers buying these products live outside the country. Despite the offshore nature of much of the production, an estimated 70 to 75 per cent of the value of imported apparel is attributed to US-based activities — including design, marketing, compliance, logistics, and retail. The association noted that footwear and travel goods are likely to reflect comparable contributions.
Sharp Rise in Apparel Import Tariffs
One of the more striking elements of the AAFA submission was the data it cited on rising apparel import tariffs. Drawing on figures prepared by Trade Partnership Worldwide, LLC, AAFA reported that the average trade-weighted tariff rate on apparel imports rose from 14.70 per cent in 2024 to 24.56 per cent in 2025. For footwear, the rate climbed from 12.26 per cent to 23.75 per cent over the same period, while travel goods saw an increase 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 — a 68 per cent jump from $16.89 billion recorded in 2024. Through August 2026, the industry had paid a further $17.90 billion in tariffs, of which around $8.23 billion represented additional duties imposed under presidential trade authorities.
Concerns Over US Tariff Policy Structure
AAFA raised specific concerns about uncertainty surrounding US tariffs imposed under Sections 301, 232, 122, and 338, stating that overlapping and frequently changing duties complicate sourcing decisions, long-term planning, and supply-chain operations. Among the remedies sought, AAFA called for a non-stacking approach to prevent multiple tariffs from applying to the same products, the removal of duties on manufacturing inputs and machinery, and exemptions for goods qualifying under existing free trade agreements. The association also requested adequate lead times for any new measures, so that businesses, supply chains, and enforcement agencies have sufficient time to understand new requirements, update systems, and implement changes.
The submission further argued that tariffs on imports containing substantial American value — including intellectual property and domestically sourced materials — ultimately raise costs for both US companies and consumers. With limited domestic alternatives available for certain goods, AAFA contended that additional duties on essential consumer products impose a disproportionate burden on businesses and families.
Country-Specific AAFA Trade Barriers
India
In India, AAFA said Bureau of Indian Standards (BIS) Quality Control Orders require factory-by-factory certification, testing and audits, along with BIS marking on each pair of footwear. The association cited certification backlogs and claimed that domestic footwear manufacturers were not subject to equivalent requirements. These rules, AAFA said, are increasing costs and making it difficult for US companies to serve the Indian market, pushing some to exit entirely.
China
In China, AAFA flagged inconsistent customs procedures, additional certificate-of-origin information requirements, unofficial reference price lists, and a lack of regulatory transparency. Customs practices were reported to vary between ports and officials, while requirements differed across provinces. The submission also raised concerns about restrictions on recycled materials used in textile production, as well as alleged retaliatory measures against US companies complying with American forced-labour laws.
Mexico
In Mexico, AAFA noted that estimated-pricing requirements continued to apply to footwear even after similar measures for textiles and apparel were removed in September 2026. Importers whose declared transaction values fall below reference prices are required to provide financial guarantees, potentially tying up capital for 12 months or longer if an investigation is initiated. Additional concerns included customs documentation and reporting requirements, and rules mandating that clothing sizes be displayed in Spanish before any other language.
Other Countries
The submission also covered a range of concerns in other markets. In Colombia, AAFA pointed to customs valuation thresholds for textile, apparel, and footwear imports. In Indonesia, expanded halal certification requirements for certain clothing, footwear, leather goods, and accessories containing animal-derived materials were flagged. Japan’s high tariff-rate quota on leather footwear was also identified as a barrier. Canadian 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.
On Haiti, AAFA noted that gang violence and political instability have disrupted the movement of raw materials and finished goods, contributed to factory closures, and discouraged investment. The association 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.
Broader Policy Requests
Beyond country-specific AAFA trade barriers, the association advocated for greater international harmonisation of chemical management, product safety, and labelling rules, arguing that diverging national requirements increase compliance costs and create delays for companies operating across multiple markets.
AAFA’s submission additionally raised concerns about the US Customs and Border Protection (CBP) 9802 programme, the Western Hemisphere Incentive Program, customs enforcement consistency, intellectual property protection, and trade preference programmes.
On digital labelling, AAFA urged support for broader adoption, stating it could reduce material waste, improve access to product information, and simplify regulatory updates. The association estimated that apparel companies produce approximately 5.7 million miles of label tape annually, generating at least 343,000 metric tonnes of carbon dioxide equivalent emissions. Digital labels, it said, could also support product recycling and improve accessibility for visually impaired consumers.
The submission further raised concerns about data localisation requirements and restrictions on cross-border data flows, as well as shipping disruptions arising from Red Sea attacks and port labour strikes.
Regarding 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 give importers greater long-term certainty.
AAFA also urged the US administration to promote implementation of the World Trade Organization’s Trade Facilitation Agreement, called for renewal of the Generalized System of Preferences — which expired on December 31, 2020 — and expressed support for longer-term extensions and reforms to the African Growth and Opportunity Act and Haiti’s HOPE/HELP programmes.
In closing, the association urged USTR to work alongside other federal agencies and industry representatives to collectively address the barriers identified throughout its submission, reinforcing the importance of coordinated action on USTR NTE report priorities for the apparel and footwear sector.
