Trade Policy
The domestic footwear industry is sensitive to imported footwear that is manufactured from countries with dramatically lower wages as well as less stringent environmental and labor practices. Footwear produced in the United States is widely recognized as the highest quality. U.S. manufactured footwear exports increased by 8.7 percent between 2013 and 2017.
Opposition to Expanding GSP to Include Footwear and Apparel
USFMA strongly opposes all efforts to remove the longstanding footwear exemptions from the Generalized System of Preferences (GSP). USFMA strongly supports the increased eligibility criteria that will hold potential GSP beneficiaries accountable for labor, environmental and human rights standards.
GSP provides duty-free treatment to roughly 120 developing countries and territories. The program is designed to help the world’s poorest nations use trade to grow their economies and climb out of poverty. A fundamental part of GSP is excluding import sensitive industries that would be damaged from cheap imports. The footwear industry has always been recognized as import sensitive domestic manufacturing industries.
USFMA believes it is important to increase the eligibility criteria for GSP’s and hold potential GSP beneficiaries accountable for labor, environmental and human rights standards as they should be moving towards the principles, we expect of FTA partners.
Any attempt to remove the longstanding exemption of footwear from GSP or lower eligibility criteria for GSP’s will fundamentally damage these American manufacturing industries and overall standards.
De Minimis
Under the current de minimis threshold (DMT) goods valued under $800 incur no import duties and are subject to minimal clearance procedures and data requirements when entering the United States through ports of entry. The limit was raised from $200 to $800 in 2016 with the passage of the Trade Facilitation and Trade Enforcement Act (TFTEA). De minimis was originally designed to ensure that American travelers could bring back to the United States a limited number of goods without incurring customs. However, over the last 10 years, U.S. Customs and Border Protection data has shown that the value of de minimis imports into the United States have risen from $40 million in 2012 to over $67 Billion in 2020. More than 10% of all imports from China arrive in the U.S. under the current de minimis exception. It is estimated that there are over 800 million de minimis shipments into the U.S annually.
USFMA strongly supports banning imports from non-market economies, such as China, from receiving the de minimis exception. In addition, USFMA supports lowering the dollar value of the de minimis exemption.
Miscellaneous Tariff Bills
Miscellaneous Tariff Bills (MTBs) is a legislative measure, if enacted into law, that creates a temporary provision in the Harmonized Tariff Schedule (HTS) which is used to classify and assess tariffs. The practice is generally viewed as a low-cost method of providing a competitive edge to U.S. businesses by reducing inputs used to manufacture downstream products, making end-use products more affordable to consumers. However, USFMA strongly opposes the inclusion of finished products in future rounds of Miscellaneous Tariff Bills (MTBs).
The MTB process was initiated to increase American manufacturing by eliminating tariffs on constituent materials used to manufacture a finished product. As the MTB process exists today, our industry faces tariff engineering, or importers designing and producing footwear that skirts tariffs on footwear that directly competes with American made footwear.
Our industry is resource strapped and we are responsible for researching every single finished product footwear MTB petition.