Trade Lawyers Blog has posted summary & analysis of a recent presentation by CBP covering the noncompliance of imported textile & wearing apparel from China. Here is an excerpt:
It has long been understood that achieving 100% trade compliance with textile and wearing apparel imports has been challenging for both Customs and the trade community. In a recent presentation, Janet Labuda, the U.S. Customs and Border Protection (CBP) Director of Textile Enforcement, reminded the audience just how daunting that challenge remains...
... Under Ms. Labuda’s direction, CBP has assembled a cross-functional team to review textile and wearing apparel imports from China. Over a relatively short period of time, the team visited 60 companies in Los Angeles, another 60 in Manhattan, and another 61 throughout the rest of the country. The result confirmed CBP’s worst fears.
- Textiles (including wearing apparel) still account for approximately 40% of all duties collected and about 22% of all import entries filed
- More than half of the importers interviewed by CBP did not have the right to make entry
Two additional examples highlighted in Labuda's presentation, summarized by Trade Lawyers Blog:
In one example, goods worth $33 million were imported by one company, but the person acting as importer was getting paid just 1¢ per garment. In other words, this person did not qualify to act as importer of record, and the value being declared at time of entry was significantly underreported. In other examples, a shipment was originally offered for entry with a value of $200,000. When Customs refused the entry, the corrected entry reflected a value of $1.7 million.
Another entry originally submitted at $250,000 was ultimately revised to $1.5 million. They had no knowledge about the goods and also had no interest in those goods.
For more info, read on at Trade Lawyers Blog, it is an excellent post!

