On April 24th, the European Apparel and Textile Confederation ("EURATEX") issued a position paper on EU-USA Trade Relations, stating "strong support" for a free trade agreement between the U.S. and the E.U.
With regard to market access (what products are to have duty reductions, the extent of the reductions, and the timing of reductions) EURATEX called for "...reciprocal elimination of all duties from day one of the agreement with no exclusion.."
With regard to non-tariff barriers EURATEX cited several state or national regulations that allegedly hinder free flow of goods --
The Consumer Product Safety Improvement Act, stating --
(a) This legislation establishes burdensome provisions for Exports of Apparel and Fabrics considered in the Flammable Fabrics Act (ex. Silk, Cotton)- General Certificate of Conformity and Testing. EU Silk producers, in particular, have been requesting for long that Silk be exempted from the tests of Standard CFR 1610, as it is already foreseen for other type of Fabrics wool, polyester, nylon, acrylic, modacrylic, olefin. Since there is no scientific evidence that Silk is more flammable than any other of the exempted materials. In fact scientific tests conducted by different EU laboratories showed no evidence of an increase flammability of Silk fabrics; (b) The legislation is even more burdensome and costlier in the case of Children’s products (under 12 years old) requiring mandatory Third Party Testing (Accredited Laboratories).
California Proposition 65.
The State of Utah's Bedding, Upholstered Furniture and Quilted Clothing Inspection Act.
The number of Customs documents that to be filled in, particularly those requiring commercially sensitive information and the duplication of information.
Security Requirements implemented after Sept 11th.
The Merchandise Processing Fee, Cotton Fee and Harbor Maintenance Fee.
Labeling requirements, stating --
Information required in the US is much more extensive and burdensome than in the EU- name of the manufacturer/ importer, indication of process operations, in case they are partially done in the US and partially done in a Third Country, country of origin and special requirements for Fur and Wool. Some of these provisions, if not entirely eliminated, could at least be simplified for EU goods. Regulatory cooperation, mutual recognition/ harmonization and the privileged use of the Suppliers Declaration should be envisaged.
The Berry Amendment which requires the use of wholly US made products in uniforms, parachute and other textile based materials used in the military field and several Departments of Homeland Security.
Regarding the Rules of Origin, EURATEX stated --
Even if in our sector there are important differences between the preferential rules normally applied by the EU and the ones applied by the US we should strive for a compromise that takes into account the interests of the Industry.
Regarding investment, the paper calls for using "...as benchmark the best provisions existing in Bilateral Investment Treaties between the US and its main EU Investment Partners."
The paper notes that raw materials is one of the most important areas where we have similar views is in the field of Access to Raw Materials. With regard to Trade Distortive Practices, the paper notes, "there is a wide range of measures and initiatives adopted by Third Countries that are harmful both to EU and US companies. These range from increased barriers to access certain markets, including Public Procurement, to currency manipulation, disrespect of IPR or state subsidies. There should be an increased cooperation between the EU and the US to jointly address these issues." The paper is available on the EURATEX website at http://euratex.eu/content/eu-usa-trade-relations-public-consultation-euratex-position-paper.