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ATPDEA Textile Provisions

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ATPDEA Textile Provisions

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    1. ATPDEA Textile Provisions U.S. Customs & Border Protection 2003

    2. Andean Trade Promotion and Drug Eradication Act H.R. 3009 Public law 107-210 Signed into law on August 6, 2002 Effective on October 1, 2002 Will expire on December 31, 2006 Andean Trade Promotion and Drug Eradication Act (ATPDEA)

    3. Colombia Ecuador Peru Bolivia

    4. Andean Trade Promotion and Drug Eradication Act (ATPDEA) Preferential treatment for certain textiles and apparel and luggage Protections against transshipment Throughout the next few days you will hear us talk a lot about apparel (clothing). Although the AGOA provides trade benefits for most products, much of the attention has focused on apparel. Within the AGOA, apparel is mentioned prominently in two sections: Section 112: Treatment of Certain Textiles and Apparel (Benefits) Section 113: Protections Against Transshipment (Obligations) These conditions, or obligations came about because of the persistent problem of illegal textile transshipment. The U.S. has dealt with the problem of illegal textile transshipment for a number of years, and therefore required the obligations to ensure the benefits go to Africa, and not to the illegal trader. The trade benefits are so great, there is a major concern about Illegal Transshipments. The AGOA Legislation took 5 years to pass thought the U.S. Congress, in part, due to the concern over illegal textile transshipment. The U.S. Government wants the AGOA benefits to go to Africa. We’ll cover the issue of Anti-Transshipment Enforcement a little latter this morning. We’ll also cover Textile Production Verification visits, (Factory Visits). Throughout the next few days you will hear us talk a lot about apparel (clothing). Although the AGOA provides trade benefits for most products, much of the attention has focused on apparel. Within the AGOA, apparel is mentioned prominently in two sections: Section 112: Treatment of Certain Textiles and Apparel (Benefits) Section 113: Protections Against Transshipment (Obligations) These conditions, or obligations came about because of the persistent problem of illegal textile transshipment. The U.S. has dealt with the problem of illegal textile transshipment for a number of years, and therefore required the obligations to ensure the benefits go to Africa, and not to the illegal trader. The trade benefits are so great, there is a major concern about Illegal Transshipments. The AGOA Legislation took 5 years to pass thought the U.S. Congress, in part, due to the concern over illegal textile transshipment. The U.S. Government wants the AGOA benefits to go to Africa. We’ll cover the issue of Anti-Transshipment Enforcement a little latter this morning. We’ll also cover Textile Production Verification visits, (Factory Visits).

    5. Trade Benefits for Andean Apparel Manufacturers Quota free Duty free

    6. U.S. Apparel Imports Total apparel imports into the U.S. Amounted to $60 billion Mexico exported $7.4 billion Andean countries exported $847 million, slightly over 1% of all apparel imports

    7. Apparel articles that are imported directly into the customs territory of the United States from an ATPDEA beneficiary country shall enter the United States free of duty and free of any quantitative restrictions, limitations, or consultation levels, but only if such articles are described in subparagraph (B).

    8. Goods classifiable in chapters 61 and 62 and headings 6501, 6502, 6503, 6504, and subheadings 6406.99.15 and 6505.90, HTSUS. 19 CFR 10.242

    9. 19 CFR 10.243(d)

    10. The article must be imported directly from an ATPDEA country to the US Three definitions of “imported directly”

    11. 1.Direct shipment from an ATPDEA to US without passing through the territory of any non-beneficiary country 2.Shipment from an ATPDEA to US through a non-beneficiary country only if: The merchandise does not enter into the commerce of any non-beneficiary country, and Invoice, bills of lading, and other shipping documents show US as the final destination

    12. 3.Shipment from an ATPDEA to US through a non-beneficiary country and the invoices and other documents do not show US as the final destination only if: Goods remained under the control of the customs authority of the intermediate country Goods did not enter the commerce of that intermediate country The transaction that causes the goods to be imported into the US must be between the US importer and the producer or the producer’s agent Goods were not subjected to operations other than loading and unloading or preservation

    13. General Rule of Origin for Apparel “Yarn forward” rule US/ATPDEA yarn and fabric

    18. All of the production processes took place in the US or in 1 or more ATPDEA country. This means, starting with the extrusion of filament, strip, film or sheet and including drawing to fully orient a filament or slitting a film or sheet into strip, or the spinning of all fibers into yarn, or both, and ending with a yarn or plied yarn. 19 CFR 10.242

    19. All of the production processes took place in a single country. This means starting with polymers, fibers, filaments, textile strips, yarns, twine, cordage, rope or strips of fabric and ending with a fabric by a weaving, knitting, needling, tufting, felting, entangling or other process. 19 CFR 10.242

    20. All of the production processes starting with the production of wholly formed fabric and ending with a component that is ready for incorporation into an apparel article, took place in a single country. 19 CFR 10.242

    21. “Knit-to-shape Components” Means components that are knitted or crocheted from a yarn directly to a specific shape containing a self-start edge. Minor cutting or trimming will not affect the determination of whether a component is “knit-to-shape.” 19 CFR 10.242

    22. “Assembled or Sewn or Otherwise Assembled in One or More Beneficiary Countries” A joining together of two or more components that occurred in one or more beneficiary countries, whether or not a prior joining operation was performed on the article or any of its components in the US 19 CFR 10.242

    23. Fabric or fabric components for apparel articles made from US knit or woven fabric must be printed, dyed and finished in the US. This requirement does not apply to non-woven fabric or fabric components. 19 CFR 10.243(b)

    24. Apparel assembled from US fabric/components 9821.11.01, HTSUS 19 CFR 10.243(a)(1)(i)

    25. Example 1 Cotton grown in US Cotton fibers spun into yarn in US Cotton yarn woven into cotton twill fabric in US Cotton twill fabric dyed and finished in US Finished fabric shipped to Ecuador Cotton twill fabric cut into components for a pair of jeans in Ecuador All components assembled in Ecuador

    26. Example 2 Cotton grown in US Cotton fibers spun into yarn in US Cotton yarn woven into cotton twill fabric in US Cotton twill fabric dyed and finished in US Cotton twill fabric cut into components for a pair of jeans in US Belt loops and waistband assembled in US Components shipped to Ecuador All components assembled in Ecuador

    27. Apparel article Chief value llama, alpaca or vicuńa fabric or components Yarns wholly formed in one or more ATPDEA beneficiary countries Fabrics or components wholly formed in 1 or more ATPDEA beneficiary countries Assembled in 1 or more beneficiary ATPDEA countries or US, or both Entered under 9821.11.04, HTSUS

    28. “Chief Value” Means that the value of those materials exceeds the value of any other single textile material in the fabric or component under consideration 19 CFR 10.242

    29. Apparel articles sewn or otherwise assembled from fabric, fabric components or components knit to shape, in chief value of llama, alpaca or vicuńa, in an ATPDEA country from yarns wholly formed in one or more ATPDEA country (including fabrics not formed from yarns, if such fabrics are classifiable under heading 5602 or 5603 of the HTSUS and are formed in one or more ATPDEA countries). 19 CFR 10.243(a)(1)(ii)

    30. Assembled from fabric, fabric components, or components knit-to-shape, in chief value of llama, alpaca or vicuńa 9821.11.04, HTSUS 19 CFR 10.243(a)(1)(ii)

    31. Example 3 Alpaca spun into yarn in Peru Nylon spun into yarn in Colombia Nylon yarn shipped to Peru Alpaca and nylon yarn woven into 55% nylon/45% alpaca fabric in Peru Alpaca fibers 70% of value of fabric Fabric cut into components for a coat in Peru All components assembled in Peru

    32. Preference Group C NAFTA short supply Entered under 9821.11.07, HTSUS

    33. “NAFTA Short Supply” Apparel articles sewn or otherwise assembled in 1 or more ATPDEA beneficiary countries, or in the US, or in both, from fabrics or yarns, provided that apparel articles (except articles of subheading 6212.10, HTSUS) of those fabrics or yarns would be considered originating goods under General Note 12(t), HTSUS, if the apparel articles were imported directly from Canada or Mexico 19 CFR 10.243(a)(1)(iii)

    34. Silk Linen Cotton velveteen Fine wale corduroy Harris tweed Certain woven fabrics made with fine animal hair Certain lightweight, high thread count polyester/cotton woven fabrics Certain lightweight, high thread count broadwoven fabrics used in the production of men’s or boys’ shirts (not a definitive list) NAFTA Short Supply

    35. NAFTA short supply 9821.11.07, HTSUS 19 CFR 10.243(a)(1)(iii)

    36. Example 4 100% linen fabric imported from Ireland Fabric cut into components for women’s blouse in Bolivia Components sewn to form a blouse in Bolivia

    37. Example 5 60% linen/40% cotton fabric imported from Egypt Polyester pocketing material imported from China Components cut in Colombia Components sewn into men’s trousers in Bolivia

    38. Preference Group D Designated short supply Entered under 9821.11.10, HTSUS

    39. “Designated Short Supply” US president, or his designee, is authorized to add additional yarns or fabrics, that can be used without regard to their origin, if such yarns or fabrics cannot be supplied by the domestic industry in commercial quantities in a timely manner 19 CFR 10.243(a)(1)(iv)

    40. “Designated Short Supply” CITA -- committee for the implementation of textile agreements has been delegated authority Http:\\www.otexa.ita.doc.gov

    41. Designated short supply 9821.11.10, HTSUS 19 CFR 10.243(a)(1)(iv)

    42. Preference Group E Combination of groupings A - D Entered under 9821.11.13, HTSUS

    43. Apparel Assembled From Any Combination of Groupings A-D Apparel articles sewn or otherwise assembled in 1 or more ATPDEA beneficiary countries, or in the US, or in both, exclusively from a combination of fabrics, fabric components, knit-to-shape components or yarns described in two or more of groupings A-D 19 CFR 10.243(a)(2)

    44. Combination of groupings A-D 9821.11.13, HTSUS 19 CFR 10.243(a)(2)

    45. Example 6 100% acrylic knit to shape components knit in US from US yarn 100% alpaca knit to shape components from Peru Assembled in Colombia into sweater with acrylic and alpaca patchwork panels Combination of groupings A and B

    46. Preference Group F Handloomed articles Handmade articles Folklore apparel or textile articles Entered under 9821.11.16, HTSUS

    47. Handloomed, Handmade, or Folklore Textile or Apparel Articles Competent authority in beneficiary country must certify articles considered handloomed, handmade, or folklore U.S. will consult with beneficiary country authorities to determine which articles, if any, will be treated as handloomed, handmade, or folklore CITA has been delegated authority to designate eligible articles 19 CFR 10.243(a)(3)

    48. Handloomed, Handmade, or Folklore Textile or Apparel Articles Must be handloomed fabric, handmade goods of handloomed fabric or traditional folklore articles. Generally apparel, apparel accessories or decorative furnishings May not include “modern” features, patterns or styles such as zippers, velcro®, etc. Please provide samples and descriptions when submitting articles to CITA for designation

    49. Preference Group F -Summary Handloomed, handmade or folklore articles 9821.11.16 19 CFR 10.243(a)(3)

    50. Preference Group G Brassieres Cut and sewn in the US, or one or more ATPDEA beneficiary countries or both Subject to value requirement Entered under 9821.11.19, HTSUS

    51. Brassieres Brassieres, classifiable under subheading 6212.10 of the HTSUS, cut and sewn or otherwise assembled in the US, or one or more ATPDEA beneficiary countries, or both. 19 CFR 10.243(a)(4)

    52. 19 CFR 10.248(b) limitations on preferential treatment (1) general. During the year that begins on October 1, 2003, & during any subsequent year, articles of a producer or entity controlling production that conform to the production standards set forth in §10.243(a)(4) will be eligible for preferential treatment only if:

    53. 19 CFR 10.248(b) Limitations on Preferential Treatment (1)(i) The aggregate cost of fabrics (exclusive of all findings and trimmings) formed in the US that were used in the production of all of those articles of that producer or that entity controlling production that are entered as articles described in §10.243(a)(4) during the immediately preceding year was at least 75% of the aggregate declared customs value of the fabric (exclusive of all findings and trimmings) contained in all of those articles of that producer or that entity controlling production that are entered as articles described in §10.243(a)(4) during that year; or

    54. 19 CFR 10.248(b) Limitations on Preferential Treatment

    55. Producer Entity controlling production Fabrics formed in the US Cost Declared customs value Year Entered Brassieres-19 CFR 10.248(a) Definitions of Terms

    56. Brassieres-19 CFR 10.248(a) Definitions of Terms

    57. Brassieres-19 CFR 10.248(a) Definitions of Terms Entity Controlling Production Individual Corporation Partnership Association Other Entity or Group Not a Producer Controls Production in ATPDEA Country through Contractual Relationship or other Indirect Method

    58. Brassieres-19 CFR 10.248(a) Definitions of Terms Fabrics Formed in the U.S. Weaving Knitting Needling Tufting Felting Entangling Other Formation Process

    59. Brassieres-19 CFR 10.248(a) Definitions of Terms Cost Price of U.S.-formed fabrics when last purchased FOB port of export, or with adjustments to reach a FOB price If unable to determine FOB price, or price is determined to be unreasonable, then a Computed Value equivalent for the fabrics plus costs representing freight, insurance, packing, and other costs to get it to port of export

    60. Brassieres-19 CFR 10.248(a) Definitions of Terms Cost Examples U.S. formed fabric, purchased FOB Miami Price paid is the “cost” U.S. formed fabric, purchased on the local (ATPDEA) market “Cost” is price paid, minus: freight and insurance, from U.S. to ATPDEA country duty paid at entry to ATPDEA country mark-up etc.

    61. Brassieres-19 CFR 10.248(a) Definitions of Terms Declared Customs Value Cost of U.S. Formed Fabric, plus Cost of All Non-U.S.-Formed Fabric Contained in Article Value of Findings/Trimmings not Included Each Figure Must be Verifiable

    62. Brassieres In first year, only requirement is that the bras be cut and sewn or otherwise assembled in the US or ATPDEA beneficiary countries or both (no US fabric content required for duty free treatment) Beginning Oct. 1, 2003, requirement that in the preceding year, the aggregate cost of US fabrics used in the production of a producer’s or entity’s bras was at least 75% of aggregate declared customs value of the fabric in all bras of that producer or entity that were entered and eligible under this provision in preceding 1-year period If fail to meet requirement, 85% US fabric requirement is imposed 19 CFR 10.243(a)(4); 19 CFR 10.248(b)

    64. Declaration of Compliance 1. Year Commencing October 1, Ending September 30 of Calendar Year in Which Applicable % Standard was Met 2. Legal Name and Address of the Preparer, Including Preparer’s I.R. Number, if Applicable 3. Legal Name(s) and Address(es) of ATPDEA Producer, if not Already Identified in Block 2 4.,5. Related to Goods Entered During Year in Block 1 6. Declare Standard: 75% or 85% 7. Signature of Authorized, Knowledgeable Person

    65. Brassieres assembled in the US and/or one or more ATPDEA beneficiary countries 9821.11.19, HTSUS 19 CFR 10.243(a)(4)

    66. Example 7 A Producer in an ATPDEA Country: In Single Calendar Year, Sends Entire Production of Goods meeting 10.243(a)(4) to the U.S. Consists of Two Shipments Shipment 1 does not Meet 75% Standard Shipment 2 Exceeds 85% Standard Shipment 1 is Entered on March 1 Shipment 2 is Entered into a Warehouse and not Withdrawn for Consumption until November 1 For that Calendar Year, Can the Producer Complete a Valid Declaration of Compliance?

    67. Preference Group H Textile luggage Assembled in ATPDEA beneficiary country Fabric/components wholly formed in US Yarn wholly formed in US Entered under 9802.00.8048 and 9821.11.22, HTSUS

    68. All fabric components used in the assembly of the article were cut from fabric in one or more ATPDEA countries, or were cut from fabric in the United States and used in a partial assembly of the article in one or more ATPDEA beneficiary countries, or both. 19 CFR 10.242

    69. Luggage-19 CFR 10.242 Travel goods, such as trunks, hand trunks, lockers, valises, satchels, suitcases, wardrobe cases, overnight bags, pullman bags, gladstone bags, traveling bags, knapsacks, kitbags, haversacks, duffel bags, and like articles designed to contain clothing or other personal effects during travel; and Briefcases, portfolios, school bags, photographic equipment bags, golf bags, camera cases, binocular cases, gun cases, occupational luggage cases (physicians’ cases, sample cases, etc.), And like containers and cases designed to be carried with the person.

    70. Luggage-19 CFR 10.242 (Continued) Luggage does not include the following: “Handbags” which include pocketbooks, purses, shoulder bags, clutch bags, and all similar articles, by whatever name known, customarily carried by women or girls; or, “Flat goods” which includes small flatware designed to be carried on the person, such as banknote cases, bill cases, billfolds, bill purses, bill rolls, card cases, change cases, cigarette cases, coin purses, coin holders, compacts, currency cases, key cases, letter cases, license cases, money cases, pass cases, passport cases, powder cases, spectacle cases, stamp cases, vanity cases, tobacco pouches and similar articles.

    71. Textile Luggage Textile luggage satisfying the criteria for eligibility will not be precluded from receiving preferential treatment because it incorporates foreign-made non-textile components. Example: leather handle However, foreign-origin findings and trimmings are subject to the 25% cost limitation. Example: zipper

    72. Textile luggage assembled in ATPDEA beneficiary country from US fabric and yarn 9802.00.8048 (US fabric cut in US) and 9821.11.22 (US fabric cut in 1 or more ATPDEA beneficiary country) 19 CFR 10.243(a)(5)&(6)

    73. Apparel sewn or otherwise assembled in 1 or more ATPDEA beneficiary countries from ATPDEA formed fabrics or components US or ATPDEA wholly Formed yarn Whether or not in Combination with Groupings A-D Subject to tariff preference level (TPL) Entered under 9821.11.25, HTSUS Preference Group I

    74. Apparel articles assembled in 1 or more ATPDEA beneficiary countries from ATPDEA fabrics or components, from yarns wholly formed in the US or 1 or more beneficiary countries (including fabrics not formed from yarns, if such fabrics are classifiable under heading 5602 or 5603 of the HTSUS and are formed in 1 or more beneficiary countries), whether or not the apparel articles are also made from any of the fabrics or components described in groupings A - D 19 CFR 10.243(a)(7)

    75. Apparel assembled in ATPDEA beneficiary countries from ATPDEA fabric/components from US/ATPDEA yarn, whether or not in combination with groupings A-D 9821.11.25, HTSUS 19 CFR 10.243(a)(7)

    76. Example 8 100% linen fabric imported from Ireland 100% cotton voile fabric woven in Colombia from yarn wholly formed in Colombia Fabric cut into components in Peru Components assembled in Ecuador to form linen blouse with sheer cotton voile sleeves

    78. Special Rules Findings & trimmings Certain interlinings De minimis Nylon filament yarn

    79. Findings and Trimmings General rule Apparel article eligible for preferential treatment under ATPDEA Findings or trimmings of foreign origin can be included IF the value of such findings and trimmings does not exceed 25% of the cost of the components of the assembled article. $ $ $ $

    80. Findings and Trimmings General rule An article otherwise eligible for preferential treatment under this section will not be ineligible for such treatment because the article contains findings or trimmings of foreign origin, if the value of those findings and trimmings does not exceed 25% of the cost of the components of the assembled article. 19 CFR 10.243(c)(1)(i)(a)

    81. Findings and Trimmings Findings - sewing essentials used in garments Trimmings- decorative or ornamental parts

    82. Findings and Trimmings Examples: Sewing thread Hooks and eyes Snaps Buttons “Bow buds” Decorative lace trim Zippers, zipper tapes Labels Elastic strips

    83. Qualifying Findings and Trimmings Reinforcing tape --analogous to zipper tape, a necessity in constructing a garment Embroidery thread, button tacks, and bias tape -- analogous to sewing thread, buttons and zipper tape “Tommy Hilfiger” patch sewn onto jeans -- is an example of a small textile ornamentation “Pooh” patch-- symbolized brand And adds ornamentation

    84. Not Considered Findings and Trimmings Velveteen upper collar of women’s jacket Shoulder pads and sleeve headers for men’s suit-type jacket Textile drawstring cord for jackets Chest pieces, suede yoke and elbow patches for men’s jackets -- yoke and elbow patches comprised a relatively large surface area and served more than mere decorative purpose unlike lace trim

    85. Certain Interlinings General rule Apparel article eligible for preferential treatment under APTDEA Certain interlinings of foreign origin can be included IF the value of such interlinings (And any foreign findings and trimmings) does not exceed 25% of the cost of the components of the assembled article $ $ $ $

    86. Certain Interlinings General rule An article otherwise eligible for preferential treatment under this section will not be ineligible for such treatment because the article contains certain interlinings of foreign origin, if the value of those interlinings (And any foreign findings and trimmings) does not exceed 25% of the cost of the components of the assembled article 19 CFR 10.243(c)(1)(i)(b)

    87. “Interlining” A fabric placed between the lining and the outer fabric of a garment as a stiffening, to give the garment shape or as padding, for extra warmth. Many different fabrics of various fibers are used, e.G., Canvas, crinoline, haircloth, flannel, padding, quilted fabric, batting webs and non-woven fabrics. Fairchild’s dictionary of textiles

    88. Certain Interlinings Eligible interlinings Type Chest type plate Hymo piece Sleeve header Construction Of woven or weft-inserted warp knit construction Of coarse animal hair or man-made filaments

    89. De Minimis Rule An article otherwise eligible for preferential treatment under this section will not be ineligible for such treatment because the article contains yarns not wholly formed in the US or one or more ATPDEA beneficiary countries if the total weight of all those yarns is not more than 7% of the total weight of the article. 19 CFR 10.243(c)(1)(i)(d)

    90. De Minimis Rule “Very small matter” Small percentage of total weight of the good can be of foreign yarns 7% maximum limit

    91. De Minimis Rule - Example Brown wool yarn formed in US White wool yarn formed in India Wool fabric woven in Peru from brown yarn and small amount of white yarn (a decorative yarn--only comprises 5% of weight of fabric) Wool fabric is cut and sewn into a jacket in Peru

    92. De Minimus Rule - Example Rayon fabric formed in US from US yarns Rayon fabric cut into front and back panels for women’s shirt to be assembled in Colombia Sheer polyester fabric formed in China Sheer polyester fabric cut into cap sleeves in Colombia (the cap sleeves are 1 % by weight of the total weight of the textiles in the shirt. Shirt wholly assembled in Colombia

    93. Special Rule for Certain Nylon Filament Yarns Apparel provided for in provisions requiring use of US formed fabric or components will not be ineligible for preferential treatment because the apparel contains specified nylon filament yarn (other than elastomeric yarn) that entered the U.S. Duty free from Israel (under U.S.-Israel free trade agreement), or Canada or Mexico (under NAFTA) 5402.10.30, 5402.10.60, 5402.31.30, 5402.31.60, 5403.32.30, 5402.32.60, 5402.41.10, 5402.41.90, 5402.51.00 Or 5402.61.00, HTSUS 19 CFR 10.243(c)(2)

    94. (Other Than Elastomeric Yarn) Elastomeric yarn = filament yarn, including monofilament, of synthetic textile material, other than textured yarn, which does not break on being extended to three times its original length and which returns, after being extended to twice its original length, within a period of five minutes, to a length not greater than one and a half times its original length. Subheading note 1(a), section XI Covers all forms of elastomeric yarn Amount of elastomeric content within a yarn does not matter

    96. ATPDEA Questions

    97. ATPDEA Question 1

    98. ATPDEA Question 1 - Answer

    99. ATPDEA Question 2

    100. ATPDEA Question 2 - Answer

    101. Customs Regulations Issues regarding the interpretation and implementation of the ATPDEA are addressed in the interim regulations published in the federal register (68 FR 14478) on march 25, 2003.

    102. Request a Binding Ruling Binding on U.S. Customs & border protection Provides certainty Ruling is Free Binding Rulings from U.S. Customs is a wonderful program. Rulings are issued for any product. This is not AGOA or Apparel specific. I’ll tell you why Binding Rulings are such a good idea. I recently had an importer contact me regarding goods in which Customs was asking for an additional 28% in duties. Apparently the importer “Assumed” the goods were classified under a low duty-rate tariff, but they were wrong. But the goods had already been sold. I’m sure the company lost money on the sale. So unless a manufacturer is certain their product qualifies for AGOA benefits, I would suggest they request a binding ruling from U.S. Customs. There is no down-side to obtaining a binding ruling. Binding Rulings from U.S. Customs is a wonderful program. Rulings are issued for any product. This is not AGOA or Apparel specific. I’ll tell you why Binding Rulings are such a good idea. I recently had an importer contact me regarding goods in which Customs was asking for an additional 28% in duties. Apparently the importer “Assumed” the goods were classified under a low duty-rate tariff, but they were wrong. But the goods had already been sold. I’m sure the company lost money on the sale. So unless a manufacturer is certain their product qualifies for AGOA benefits, I would suggest they request a binding ruling from U.S. Customs. There is no down-side to obtaining a binding ruling.

    103. ATPDEA Information on the Internet Duty rates (HTS) www.usitc.gov Customs & BP www.cbp.gov Textile trade data www.otexa.ita.doc.gov U.S. Trade rep www.ustr.gov

    104. Questions?

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