NAFTA TPLs an Outlier among US FTAs

Among the more contentious topics in the NAFTA re-negotiation has been the topic of Tariff Preference Level ("TPL"), the provisions for a limited quantity of textile products to received the NAFTA duty-free benefit even though they fail to satisfy the NAFTA rules. The are separate TPLs depending on the type of fiber and which international border is being crossed.

Yarn TPL

Cotton and MMF spun yarn:
Canada to U.S., 11.7 million kgs.
U.S. to Canada, 1 million kgs.
Canada to Mexico, 1 million kgs.
Mexico to Canada, 1 million kgs.
Mexico to U.S., 1 million kgs.
U.S. to Mexico, 1 million kgs.

Cotton and MMF Fabric/Made-ups:

Canada to U.S., 35 miilion sme knit and 35 million sme woven.
U.S. to Canada 2 million sme knit.
Canada to Mexico 7 million sme knit or woven.
Mexico to Canada 7 million sme knit or woven.
Mexico to U.S. 18 million sme knit.
Mexico to U.S. 6 million sme woven.
U.S. to Mexico 2 million sme knit or woven.

Apparel TPL, Cotton and MMF

Canada to U.S. 80 million sme.
U.S. to Can. 9 million sme.
Canada to Mexico 6 million sme.
Mexico to Canada 6 million sme.
Mexico to U.S. 45 million sme.
U.S. to Mexico 12 million sme.

Wool

Canada to U.S. 5.1 million sme.
U.S. to Canada 0.9 million sme.
Canada to Mexico 0.3 million sme.
Mexico to Canada 0.3 million sme.
Mexico to U.S. 1.5 milion sme.
U.S. to Mexico 1 million sme.

The U.S. has 14 FTAs with 20 nations. NAFTA is the only one of these agreements with permanent unchanging TPLs.

Half of the U.S. FTAs, those with seven nations, Australia, Colombia, Israel, Jordon, Korea, Panama, and Peru, were, from implementation, without TPLs.

An arguments can be made that TPLs should not be permanent. They may be justified in the short term as addressing lack of regional supply, but the point of a free trade agreement is to build up regional capacity. The following five FTAs contain TPLs that expire:

• The Singapore FTA went into effect in 2004 with a 25 million sme TPL for cotton and MMF apparel, which was phased out over 8 years.

• The Morocco FTA went into effect in 2006 with a 30 million sme TPL that was phased out over ten years.

• DR-CAFTA went into effect with a 100 million sme TPL for Nicaragua and a 1 million sme TPL for Costa Rica, both of which have expired per the agreement.

• The Bahrain FTA went into effect in 2006 with a 65 million sme TPL, which expired in the middle of last year per the agreement.

• The Oman FTA went into effect in 2009 with 50 million sme TPL, which is scheduled to expire ten years after implementation.

In addition to NAFTA, only the Chile FTA, which went into effect in 2004, has a permanent TPL for cotton and MMF fabric of 1 million sme. However, the TPL for cotton and MMF apparel, which started at 2 million sme, was reduced to 1 million sme after ten years.

Marine Uniform Contract Awarded

American Apparel Inc., Selma, Alabama, has been awarded a maximum $48,411,186 firm-fixed-price, indefinite-delivery/indefinite-quantity contract for combat utility uniforms. This is an 18-month base contract with one 18-month and two one-year option periods. Maximum dollar amount is for the life of the contract. This was a competitive acquisition with four responses received. Location of performance is Alabama, with an Oct. 24, 2022, performance completion date. Using military service is Marine Corps. Type of appropriation is fiscal 2018 through 2023 defense working capital funds. The contracting activity is the Defense Logistics Agency Troop Support, Philadelphia, Pennsylvania (SPE1C1-18-D-1008).

Commercial Customs Operations Advisory Committee to Meet November 14th

The Commercial Customs Operations Advisory Committee (COAC) will hold its quarterly meeting on Tuesday, November 14, 2017 in Washington, DC The meeting will be open to the public.

The COAC will hear from the following subcommittees on the topics listed below and then will review, deliberate, provide observations, and formulate recommendations on how to proceed:

1. The Trade Enforcement & Revenue Collection (TERC) Subcommittee will discuss new TERC recommendations and provide any necessary updates from the Anti-Dumping and Countervailing Duty, Bond, Forced Labor, and Intellectual Property Rights Working Groups.

2. The Global Supply Chain Subcommittee will present the status of a pilot that will test the utilization of existing Automated Commercial Environment (ACE) automation in the pipeline mode of transportation. The committee will also discuss the progress of the Global Supply Chain Subcommittee's new Emerging Technologies Working Group.

3. The One U.S. Government Subcommittee will continue discussions on the progress of the Fish & Wildlife Service Working Group and will present the final white paper on the Harmonized Tariff Schedule (HTS) project. The subcommittee will also discuss the progress of the newly created Technical and Operational Outages Working Group.

4. The Exports Subcommittee will discuss the Post Departure Filing (PDF) Working Group's progress on the implementation plan of the PDF Proposal and will include steps to initiate a proof of concept. The subcommittee will also discuss the progress of the Manifest Working Group and progress on issues with the ongoing manifest pilots. The working group may present recommendations in the area of manifest timelines during the November meeting.

5. The Trusted Trader Subcommittee will continue the discussion for an enhanced Trusted Trader program that includes engagement with CBP to include relevant partner government agencies with a potential for international interoperability. A review of the pilot program status and benefits will also be undertaken in parallel to determine the optimum benefits that would be assigned to Trusted Trader participants.

6. The Trade Modernization Subcommittee will discuss its plans for the topics that will be addressed during the next quarter.

IMPORTANT NOTICE to Clients and Associates

On October 31, 2017, David Trumbull, principal, Agathon Associates, will be speaking at Global Expo Botswana, an annual business-to-business exhibition organised and managed by the Botswana Investment and Trade Centre, an agency of the Government of Botswana mandated with attracting export oriented investments into Botswana and increasing regional and international market accessibility for locally manufactured goods and services.

The Botswana Investment and Trade Conference, in the capital city Gaborone, will feature investment and trade topics deliberated by both global and regional lead speakers and panellists. Trumbull will be panelist on the topic, "How can the textiles sector in Botswana be revamped in order to fully take advantage of the global markets."

PLEASE NOTE that David will have extremely limited ability to respond to phone calls or email from Sunday, October 29th, through Thursday, November 2nd.

National Industries for the Blind Awarded Army Contract

National Industries for the Blind, Alexandria, Virginia, has been awarded a $12,884,595 modification (P00004) exercising the first one-year option period of a one-year base contract (SPE1C1-17-D-B003) with four one-year option periods for the advanced combat helmet pad suspension system. This is a firm-fixed-price, indefinite-delivery/indefinite-quantity contract. Locations of performance are Virginia, Pennsylvania and North Carolina, with an Oct. 26, 2018, performance completion date. Using military service is Army. Type of appropriation is fiscal 2018 through 2019 defense working capital funds. The contracting activity is the Defense Logistics Agency Troop Support, Philadelphia, Pennsylvania.

Trade Subcommittee Chairman David Reichert (R-WA) Announces Hearing on Miscellaneous Tariff Bill

The Committee is preparing legislation to implement recommendations made by the U.S. International Trade Commission (ITC) in its final report. The hearing will take place on Wednesday, October 25, 2017, in 1100 Longworth House Office Building, beginning at 2:00 PM.

The ITC’s final report, submitted to Congress consistent with the new MTB process established by the American Manufacturing Competitiveness Act of 2016, is publicly available and can be accessed here: https://mtbps.usitc.gov/external/. The Act provides that the legislation to be considered by Congress may not include any provision unless it was the subject of a petition submitted to the ITC and was deemed by the ITC to meet the MTB tests established in the Act, including that there is no domestic producer of a like product who objects to the provision. In view of the limited time to hear witnesses, oral testimony at this hearing will be from invited witnesses only. However, any individual or organization may submit a written statement for consideration by the Committee and for inclusion in the printed record of the hearing.

READ MORE.

Dept. of Defense Clothing Contracts Awarded

UNICOR/Federal Prison Industries, Washington, District of Columbia, has been awarded a maximum $12,564,000 modification (P00007) exercising the second one-year option of a one-year base contract (SPE1C1-16-D-1008) with two one-year option periods for Army physical fitness jackets. The modification brings the maximum dollar value of the contract to $36,854,000 from $24,390,000. This is a firm-fixed-price, indefinite-delivery/indefinite-quantity contract. Locations of performance are Virginia, Florida, Arizona, and Washington, District of Columbia, with an Oct. 29, 2018, performance completion date. Using military service is Army. Type of appropriation is fiscal 2018 through fiscal 2019 defense working capital funds. The contracting activity is the Defense Logistics Agency Troop Support, Philadelphia, Pennsylvania.

Excel Manufacturing Corp., El Paso, Texas, has been awarded a maximum $8,790,860 modification (P00121) exercising the fourth one-year option period of a one-year base contract (SPM1C1-14-D-1006) with four one-year option periods for various types of coats and trousers. The modification brings the maximum dollar value of the contract to $34,111,503 from $25,320,643. This is a firm-fixed-price, indefinite-delivery/indefinite-quantity contract. Location of performance is Texas, with an April 22, 2019, estimated performance completion date. Using customers are the Air Force and the Afghanistan government. Types of appropriation are fiscal 2018 through 2019 defense working capital and foreign military sales funds. The contracting activity is the Defense Logistics Agency Troop Support, Philadelphia, Pennsylvania.

Dept. of Commerce Preliminary Findings on Health and Competitiveness of U.S. Textile Industy

In other news, the U.S. Commerce Department’s Bureau of Industry and Security ("BIS") launched a survey and assessment of the health and competitiveness of the U.S. textile, apparel, and footwear industry in 2016. When completed, the findings will update a similar study done in 2003, and will cover topics including employment, production, competitors and customers, supply chain, financial information, research and development, effectiveness of the Berry Amendment, and future industrial challenges. The BIS team is now prepared to share preliminary findings of the study that will be unveiled later this year.

To register for a joint National Council of Textile Organizations ("NCTO") and American Apparel & Footwear Association ("AAFA") webinar on BIS's preliminary findings TODAY AT 2:00 EDT: click on the link below:

https://attendee.gotowebinar.com/register/5518592182122119427

DLA Troop Support Clothing & Textiles

Thank's to the National Council of Textile Organzations for pointing us to a plethora of information relating to U.S. Department of Defense planned textile and clothing acquisitions found at http://www.dla.mil/TroopSupport/ClothingandTextiles/CTIndustry/VendorsFAQ.aspx.

CPCS Attending the American Home Furnishings Alliance Regulatory Summit

On October 25, 2017, Andrew Lock and Allyson Tenney, Consumer Product Safety Directorate for Laboratory Sciences will attend the American Home Furnishings Alliance Regulatory Summit with industry representatives at The Conference Center at Guilford Technical Community College, Colfax, North Carolina.

Cotton Incorporated Launches free on-line learning facility

The African Cotton & Textile Industries Federation ("ACTIF") congratulates Cotton Incorporated on their latest initiative "Cotton University". This is a free on-line educational facility, delivering learning opportunities that can be accessed wherever you are and in your own time and covering a wide range of subjects applicable to our cotton, textile and apparel industries. For more details and to register see https://cottonuniversity.org/login/

Textile Industry Mourns the Loss of Ken Langley

With great sorrow we report the sudden death, Saturday, October 14th, of Ken Langley.

Ken was the owner of K D Langley Fiber Services, a textile fiber testing laboratory. Ken also taught Textiles at UMass Dartmouth (Chancellor Professor) from 1968 to 2012. He was very active in the New England Section of the American Association of Textile Chemists and Colorists.

The arrangements are at Hathaways funeral home in Fall River, Massachusetts, Wednesday, the 18th, from 4-7pm. The church service is Thursday, the 19th, at 1 p.m., at Holy Trinity Episcopal Church, 1956 Main Rd Tiverton, R.I. 02878.

Smart Fabrics Summit, April 24, 2018, Washington, D.C.

Registration Opens November 2017!

MORE INFORMATION

Smart Fabrics: Getting Smarter

Emerging Trends in Research, Technology and Public Policy

Advances in technology have brought together the apparel, technology, and textile industries to develop new capabilities in fabrics with the potential to change how athletes, patients, soldiers, first responders, and everyday consumers interact with their clothes and other textile products.

Known as “smart fabrics,” these new high-tech products have the ability to interact with their user or the environment, including tracking and communicating data about their wearer or environment to other devices through embedded sensors and conductive yarns. The applications for these new capabilities are broad with most smart fabric product development currently seen in the fields of defense, sports/fitness, health, and public safety.

Reaching the market’s full potential will require not just overcoming technical challenges but also bridging differences in how these distinct industries approach product development and addressing various public policy issues, including trade policy.

To foster greater collaboration between the U.S. apparel, technology, and textile industries and to identify the public policies that could accelerate the design and manufacture of smart fabrics products by U.S. companies, the Department of Commerce in partnership with the Industrial Fabrics Association International will host the “Smart Fabrics: Getting Smarter” Summit on Monday, April 24, 2018. This event will build on the success of the 2016 Smart Fabrics Summit and highlight emerging trends and new technology in this growing market.

Through a day of panel discussions and industry demonstrations, the Summit will:

Bring together industries that need to collaborate in order for the emerging smart fabrics industry to meet its full potential and accelerate its development by U.S. manufacturers; Improve mutual understanding of the needs of private sector industries and the roles of public sector agencies; and Spur original thinking among public and private sector organizations about how new or existing policies affect current and future smart fabrics products.

The issues that will be explored at the Smart Fabrics Summit include: (1) research and development funding, (2) intellectual property, (3) standards, (4) data security and privacy, and (5) product development trends.

Notations Inc. settles $1 million civil suit for falsifying invoices

Pursuant to an investigation led by U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) New York, and U.S. Customs and Border Protection (CBP), Notations, Inc. (Notations), a garment wholesaler based in Warminster, Pennsylvania, with a showroom in New York, has settled civil fraud claims brought under the False Claims Act.

As alleged in the complaint, Notations repeatedly ignored warning signs that its business partner, which imported garments from China, was engaged in a scheme to underpay customs duties owed on the imported garments it sold to Notations. Pursuant to the settlement, Notations admits and accepts responsibility for failing to act in response to indications of fraudulent conduct, agrees to pay $1 million in damages, and agrees to implement measures designed to prevent future fraud by Notations or its business partners.

“Evading the payment of customs duties to increase profit is not a victimless crime; it has a negative effect on the U.S. economy and law-abiding importers. HSI special agents will continue to work diligently with the officers of CBP to locate these offenders and put an end to their fraudulent business practices,” stated Special Agent in Charge of HSI New York, Angel M. Melendez. “As global supply chains grow more complex, it is important for American businesses to know their suppliers and be confident of their integrity. The outcome of this case is a testament to the dedication of our partners in the United States Attorney’s Office, Homeland Security Investigations, and the men and women of CBP in enforcing our nation’s trade laws and holding accountable those perpetrating this type of fraud,” said CBP Acting Director Leon Hayward.

As alleged in the complaint-in-intervention filed last year, Yingshun Garments, Inc. (Yinghsun), an importer of women’s apparel manufactured in China, and Import Global Designs Inc. (Import Global) and Olgrem, LLC (“Olgrem”), successor entities to Yingshun, and Marie Rogers, an owner and/or officer of each entity, engaged in a double-invoice scheme whereby Yingshun (and later Import Global and Olgrem) presented false and fraudulent invoices to CBP, showing prices for imported garments that were discounted by 75 percent or more, for the purpose of avoiding customs duties on the garments. Notations, which was Yingshun’s biggest customer, aided the fraudulent scheme by ignoring warning signs that Yingshun’s irregular business practices were highly suggestive of fraud.

As part of the settlement, Notations agreed to pay $1 million in damages. Notations also admits and accepts responsibility for its failure to take action in response to multiple warning signs that Yingshun, Import Global and Olgrem were undervaluing their imported goods and therefore paying less in import duties than they should have been paying. Notations also has agreed to implement a written compliance policy which will include measures to educate its employees on identifying red flags for fraud in import transactions, to monitor the conduct of its business partners who act as importers of overseas goods and to report all potentially fraudulent conduct to CBP.

This matter was initiated by a relator pursuant to the qui tam provisions of the False Claims Act, 31 U.S.C. § 3729 et seq. Claims against Yingshun, Import Global, Olgrem and Marie Rogers remain pending. The government’s case is being prosecuted by the U.S. Attorney for the Southern District of New York Office’s Civil Frauds Unit.

New York man admits to trafficking more than $2.5 million in counterfeit footwear

A Staten Island, New York, man concedes he planned to distribute more than $2.5 million of counterfeit UGG-brand boots that were shipped into the Port of Newark. This confession is a result of an investigation by U.S. Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI), with assistance from U.S. Customs and Border Protection (CBP).

Shi Wei Zheng, 42, pleaded guilty before U.S. District Judge John Michael Vazquez in Newark federal court to one count of trafficking in counterfeit goods. HSI special agents arrested Zheng, who was charged by complaint on March 7, 2017.

According to documents filed in this case and statements made in court:

From September 2016 through February 2017, Zheng received certain shipping container numbers from an individual overseas that identified at least three containers containing counterfeit UGG boots. Cheng asked individuals working at the Port of Newark to remove the containers from the port before they could be examined by U.S. Customs and Border Protection. Once the containers were removed, Zheng directed that they be delivered to other individuals working for him, who would then distribute the boots in New Jersey and elsewhere.

However, before Zheng could distribute the goods, HSI and CBP intercepted the containers, examined their contents, and determined the boots were counterfeit. At no time was Zheng authorized to import authentic or counterfeit UGG merchandise.

In total, Zheng trafficked in over 15,000 pairs of counterfeit UGG boots, with a total estimated retail value of over $2.5 million. Zheng also paid individuals over $50,000 in exchange for the delivery of the containers.

The trafficking in counterfeit goods charge carries a maximum potential penalty of 10 years in prison and a $2 million fine. Zheng will be sentenced on Jan. 23, 2018.

Boat Manufacturer Files for FTZ, Excludes Textiles from Request

The Richland-Lexington Airport District, grantee of FTZ 127, submitted a notification of proposed production activity to the FTZ Board on behalf of BGM America, Inc. (BGM), located in Marion, South Carolina. The notification was received on September 27, 2017.

The BGM facility is located within Subzone 127C. The facility is used for the production of sailboats, cabin cruiser powerboats, and outboard motor boats. Pursuant to 15 CFR 400.14(b), FTZ activity would be limited to the specific foreign-status materials/components and specific finished products described in the submitted notification (as described below) and subsequently authorized by the FTZ Board.

Production under FTZ procedures could exempt BGM from customs duty payments on the foreign-status materials/components used in export production (estimated 5-20 percent of production). On its domestic sales, for the foreign-status materials/components noted below, BGM would be able to choose the duty rates during customs entry procedures that apply to sailboats, cabin cruiser powerboats with inboard engines, and outboard motorboats (duty rates range from 1%-1.5%). BGM would be able to avoid duty on foreign-status components which become scrap/waste. Customs duties also could possibly be deferred or reduced on foreign-status production equipment.

The materials/components sourced from abroad include: Primers; adhesive acrylic; surface cleaning kits; liquid adhesives; spray adhesives; polyvinyl chloride profiles; plastic pipes and fittings; plastic flexible hoses; plastic tubes; plastic hoses; plastic pipes; plastic elbow fittings; wall and ceiling non-skid molding kits with adhesive backing; pavement marking tape; decal tape rolls; velcro; acrylic vessel covers; engine room foam (non-textile); plastic straps (non-textile); lamination and edge banding (non-textile); paper reinforced laminate; lavatories; plastic crates; plastic bags; plastic carboys and bottles; plastic waste bins; plastic dinnerware sets; plastic cups and serving ware; plastic kitchenware; plastic window screens; plastic doors; plastic container doors; plastic screens; plastic and woven fabric blinds; plastic boxes with lids; plastic door and cabinetry knobs; stern tube epoxy; fiberglass reinforced plastic deck parts and components; plastic wrap; plastic bushings; rubber profiles; rubber hoses with fittings; rubber hose harnesses; rubber non-skid mats; silicone gaskets and seals; rubber door stops; rubber noise dampening components; wood moldings; hardwood marine plywood with high pressure laminate outer covering; hardwood plywood veneer panels; hardwood marine plywood with hardwood veneer outer plywood; densified wood blocks; composite wood blocks; marine wood cabinetry; log books; binders and folders; watertight labels; self-adhesive labels; coated paper gaskets and washer seals; manuals; decal transfers; woven nylon strips; rubber thread and cord bungee cords; synthetic fiber braided cord cut to length; cotton netting; twine, cordage and rope safety ladders; twine and cordage rope; nylon woven ribbons; marine vinyl composed of polyvinyl chloride, polyester and cotton (coated with over 70 percent polyvinyl chloride); rubberized textile adhesive tape; textile felt seals and gaskets; synthetic fiber curtains; synthetic fiber textile blinds; synthetic fiber table covers; synthetic fiber textile wheel covers; sails of synthetic fibers; cotton dust cloths; polyester web fabric straps; abrasive deck surface coating; mirrors; nonwoven fiberglass mats; woven fiberglass with fibers; fiberglass in bulk; stainless steel threaded pipes; stainless steel support posts; stainless steel anchoring mechanisms--wire, ropes and cables; iron and nonalloy steel anchoring chains; steel nails; steel screw hooks; self-tapping steel wood screws; steel flat screws; steel bolts; steel screws; steel metal disc fasteners; steel nuts; steel finish nuts; steel spacer washers; steel cotters and cotter pins; steel nuts with flat head; iron and steel stoves; steel and iron stove parts and accessories--cooking chambers, surface panels, door assemblies, panels, windows and insulation; iron and steel sheaths for air heaters; stainless steel sinks; cast iron centerboards; steel ladders; steel flush rings; brass inserts; threaded brass reducers; copper and stainless steel pin cables; copper and stainless steel barrel bolts; brass plumbing fittings; copper hooks; aluminum tubes; aluminum pipe fittings and inserts; aluminum profiles for door and window frames; aluminum door steps; aluminum fuel tanks; aluminum blind rivets; aluminum screens; aluminum plates and castings; lead sealed in bags, used as weight; zinc thrusters; metal drill heads; metal hand tools; stainless steel kitchen utensils; base metal locks; base metal spring bolts; iron and steel interior hinges; brass hinges; iron and steel straps and buckles; iron and steel mountings, fittings, and door closers; iron and steel handles; iron and steel doorstops, chain door fasteners, door pulls and kick plates; iron and steel lid supports; iron and steel knobs and arms; iron and steel racks; iron and steel staples; marine propulsion engines; cable control gear boxes; iron and steel mountings for flaps; aluminum table legs; pumps; water pumps; air conditioner drain pumps; plastic pump fittings; inflator pumps; blowers; parts of ducting and relays that are parts of a marine air conditioning system; refrigerators; refrigerator door pivots; water purifying filters; oil and fuel filters for internal combustion engines; electric winches; winches; anchors; cast iron cover plates; sandblast guns; controls and thrusters; rudders; pressure valves; showerhead and hose valves; fresh water inlet systems; bushings; pulleys; couplings; metal glands with rubber inserts; ship propellers; electric motors (not exceeding 37.5 W); linear actuators; diesel generators; converters; regulators; inverters; tilting light signals; wiper arms; microwave ovens; water heaters; speakers; TV antenna splitters; remote controls; antennas; alarms; breakers; fuses; battery breakers; insulators; relay timers; switches; cable TV splitters; fuse holders; terminals; electrical splices; electrical couplings; junction boxes; motor control panels and controllers; switch frame out-boards; cover boxes for switches; diodes; solar panels; copper cables; coaxial cables; battery switches; HDMI cables; copper conductors; insulated plastic fittings; insulated plastic cable ducts; steering wheels; steering chains; compasses; navigation instruments; stencils; gauges; remote chain meters; electrical meters; bubble testers; water tank gauge beam parts; upholstered seats and accessories; sliding seat support system; wood furniture; plastic engine panel covers; wood and metal furniture parts; mattresses; cotton seat cushions and pillows; LED light ropes; indicator lights; wall lamps; wood touch up markers; crayons; pencil leads; and, pastels (duty rates range from free to 8.5%).

The request indicates that solar panels are subject to antidumping/countervailing duty (AD/CVD) orders and hardwood plywood is subject to an AD/CVD investigation when imported from certain countries. The FTZ Board's regulations (15 CFR 400.14(e)) require that merchandise subject to AD/CVD orders, or items which would be otherwise subject to suspension of liquidation under AD/CVD procedures if they entered U.S. customs territory, be admitted to the zone in privileged foreign status (19 CFR 146.41).

The applicant also indicates that the following foreign-sourced materials/components will be admitted to the subzone in privileged foreign status, thereby precluding inverted tariff benefits on such items (where applicable): Plastic and woven fabric blinds; woven nylon strips; rubber thread and cord bungee cords; synthetic fiber braided cord cut to length; cotton netting; twine, cordage and rope safety ladders; twine and cordage rope; nylon woven ribbons; marine vinyl composed of polyvinyl chloride, polyester and cotton (coated with over 70 percent polyvinyl chloride); rubberized textile adhesive tape; textile felt seals & gaskets; synthetic fiber curtains; synthetic fiber textile blinds; synthetic fiber table covers; synthetic fiber textile wheel covers; sails of synthetic fibers; cotton dust cloths; polyester web fabric straps; nonwoven fiberglass mats; woven fiberglass with fibers; fiberglass in bulk; mattresses; and, cotton seat cushions and pillows.

Public comment is invited from interested parties. The closing period for their receipt is November 13, 2017.

Until 2009 most textile articles were not eligible for consideration for an FTZ operation. Since then there have been several applications relating to textiles and in each case where the U.S. textile industry objected because they were willing and able to supply the textile article in question, the application was denied in whole, or at least as regards the textile component that was available from a domestic source. It appears that the applicant in this case recognized that they were unlikely to succeed in getting FTZ benefits for the textile components and that excluding textiles from the application would avoid having the whole application held up due to a dispute over textiles.