USFIA and Retailers Oppose Hiking Tariffs; NCTO Says Bangladesh, India, Vietnam Should Be Targets

The United States Fashion Industry Association noted that the U.S. average most-favored nation-applied tariff on apparel imports is 11.7%, higher than China's 6.8% and the EU's 11.5%, so tariffs on these products should be lowered to create reciprocity. For fabrics, the U.S. average tariff is 8%, China's is 7%, and the EU's is 6.6%, their submission said.

"For decades, the U.S. has had higher tariffs on apparel and textile imports than on any other industrial good. These high tariffs have done nothing to stop apparel and textile production jobs from moving to countries with lower per capita incomes than the United States," USFIA wrote. More than 90% of apparel is imported. But, they noted, that means higher-paying American jobs dominate in the United States fashion industry, such as design, product development, logistics and sourcing.

USFIA said non-supervisory textile production jobs were 74,200 in 2025, down from 203,700 30 years earlier.

The National Retail Federation said that while the first Trump trade war didn't lead to inflation, "today’s economy is very different than the 2018-19 economy when President Trump first initiated tariffs." It said that back then, many companies were able to absorb some of the cost of tariffs because the corporate tax rate dropped from 35% to 21%. That rate still exists today, but "they are not in a position again to use the savings to mitigate tariffs costs."

The NRF, like some other commenters, said it's hard to make a substantive comment "because there is a great deal of uncertainty regarding exactly what potential 'reciprocal' tariffs will mean." It would support dropping tariffs on apparel and footwear to match other countries' levels. It also criticized the allegation that value-added taxes are a trade barrier. "VATs are not tariffs," the group wrote.

"While there are continuing references to 'if they charge us, we will charge them,' it is very difficult for businesses, especially retailers, to plan, prepare and comment on this. Is USTR considering a country-wide tariff or looking at tariffs on an HTS-by-HTS line item? We strongly suggest reciprocal tariffs be used as a targeted tool for specific goods where there is an imbalance, and the U.S. has the capacity to manufacture and export goods into a targeted country."

It asked that any proposal include a process for notice and comment, and include a fair and transparent exclusions process.

"If reciprocal tariffs are so high that most Americans cannot afford retail goods, this will lead to lost sales and potential store closures and lost jobs from the nation’s largest private-sector employers," NRF wrote.

The Retail Industry Leaders Association shared a table of finished metal goods that are now subject to 45% to 75% tariffs, and said that more tariffs could harm companies and consumers. Negotiating FTAs would be preferable, it said.

It also focused on process, saying the lack of specificity in the notice means the public cannot offer informed comments. "Thus, USTR must provide new notice and comment periods for specific tariff actions. We also encourage public hearings following the announcement of specific tariff actions to ensure that stakeholders can weigh in with more targeted feedback regarding any proposed measures and assist USTR in avoiding undue burden to U.S. businesses and consumers."

It said that a realistic timeline for CBP to implement the changes is necessary. "The recent amendments to Executive Orders reinstating de minimis for Canada, Mexico and China as well as the recent decision to apply Section 232 tariffs to derivative products, illustrate the importance of having systems and processes in place with clear guidance for the trade community before actions are implemented."

The National Council of Textile Organizations, which represents textile manufacturers, which they say employ 471,000 workers, said reciprocity should not mean lowering tariffs on imports.

"Rather, reciprocity should hold bad actors accountable for systemic unfair trade practices that have hurt domestic manufacturers. The administration must calibrate tariffs to address the economic harm resulting from production overcapacity, state-sponsored subsidies, unethical labor and environmental practices (including forced labor and depressed wages), currency manipulation, artificial pricing and dumping, and other predatory trade practices."

It said that a $99.8 billion trade deficit in textile and apparel in 2024 is "directly tied" to Chinese and Asian apparel exports. "As a result, since the late 1990s the domestic textile and apparel industry has witnessed a 60 percent decline in annual output, a loss of $100 billion a year in sales. Over this same period, this great U.S. industry has also lost nearly 900,000 jobs nationwide -- a decline of 65 percent."

They said tariffs "significantly higher" than the current 20% or 27.5% on chapters 61 through 63 products from China should be imposed, and said significant tariffs should be imposed on finished textile and apparel products from countries that rely on Chinese inputs, including Vietnam, Bangladesh and India. They also argued that the African Growth and Opportunity Act is a transshipment portal for Chinese inputs.

They said that CAFTA-DR and USMCA countries should continue to have duty-free exports for qualifying textile and apparel. "Penalty tariffs on imports from these countries would be catastrophic to companies in our sector," NCTO wrote.

NCTO also asked the administration to end de minimis immediately, and to revoke the first sale rule, which establishes the cost of the goods that tariffs are applied to, which it says considerably lowers duties and is prone to abuse, and called it "nonsensical."

It said that ending de minimis and first sale "would conservatively add $70 billion dollars to the U.S. Treasury, onshore more critical production, and help address the migration issues in the Western Hemisphere."