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THE NEED TO UNMASK HIDDEN TRENDS IN FILM AND BAG IMPORTS Karen Bland Toliver FBF 2006 Annual Spring Conference April 4, 2006. © The Society of the Plastics Industry, Inc. All rights reserved. COLLECTION OF U.S. IMPORT DATA.
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THE NEED TO UNMASK HIDDEN TRENDS IN FILM AND BAG IMPORTS Karen Bland Toliver FBF 2006 Annual Spring Conference April 4, 2006 © The Society of the Plastics Industry, Inc. All rights reserved.
COLLECTION OF U.S. IMPORT DATA • International Convention on the Harmonized Commodity Description and Coding System • Administered by the World Customs Organization (WCO) • 169 members, covering 98% of world trade • Standardized tariff nomenclature (at the 6 digit level) • Basis for customs tariffs and publication of foreign trade statistics
COLLECTION OF U.S. IMPORT DATA • Harmonized Tariff Schedule of the U.S. (HTS) • Embodies the 6-digit Harmonized System (HS) • “National” break-downs at the 8 and 10 digit levels • Distinct from industry coding systems, e.g.,NAICS/SICS • The official basis for collecting trade statistics • International Trade Commission (ITC) • Responsible for reviewing and recommending changes • Conformity with HS amendments • HTS reflects changes in technology and trade patterns • Alleviate unnecessary burdens
HTS Categories for Film Imports • Captured under HTS 3920 • Non-self adhesive plates, sheet, film, non-cellular and not combined with any other materials • HTS 6-digit level is based on polymer content • e.g., “of polymers of ethylene” • HTS 10-digit level has some break outs based on other physical characteristics, e.g., flexible • Twenty-eight HTS 8-digit categories for non-self adhesive plates, sheet, and film products
PE Film Import Statistics Import Values Import Quantities Million lbs. $ Million $847 618 552 $ 712 455.5 $ 575 Source – U.S. Official Trade Stats, ITC Trade Database
PE Film Top 5 Import Sources - 2005 • In ’05, Canada shipped 372.6 million lbs. • Mexican imports grew by 113%, from • 15.2 million lbs. in ’04 to 32.4 million lbs. in ’05 – due to intra-company transfers? • Chinese imports increased by 31%, from 24.2 million lbs. in ’04 to 31.7 million lbs. in ‘05. • Malaysia was not in the top 5 sources based on value, but was ranked # 5 based on quantities. Malaysian imports grew by 170%, from 7.9 million lbs. in ’04 to 21.5 million lbs. in ’05. *Ranked by import volumes Source – ITC Trade Database
PE Film Imports by Port of Entry - 2005 Source – ITC Trade Database
Questions/Issues • Does the HTS category for PE film reflect business reality? • Is it adequate to accurately monitor/track imports? • Would the industry benefit from more specific break-downs? • If so, where are the “clear dividing” lines?
HTS Categories for Bag Imports • Captured under HTS 3923 • Articles for the conveyance or packing of goods, of plastics, stoppers, lids, caps and other closures • HTS 8-digit level is based product type • e.g., boxes vs. bags vs. bottles vs. stoppers/lids • HTS 10-digit level categorizes bags based on limited physical properties, e.g., PE vs. other plastics • Recent modification to break out PE retail carrier bags with handles • Only six HTS 10-digit categories for PE plastic bags
HTS Categories for PE Plastic Bags • Re-closable PE bags with no single side exceeding 75 millimeters in length • Re-closable bags with integral extruded closure • Non re-closable PE bags with no single side exceeding 75 millimeters in length • PE retail carrier bags with handles • Non re-closable PE bags • All other PE bags
Total PE Bag Import Statistics Import Values Import Quantities 1,000 units $ Million $ 1.2 B 203 $946 151 $ 776 126 Lbs. 1.9 B 2.3 B 3.0 B Conversion Factor – 15 lbs per 1,000 units Source – U.S. Official Trade Stats, ITC Trade Database
PE Bag Imports by Port of Entry - 2005 Source – ITC Trade Database
Top 5 Import Sources – 2005PE Retail Carrier Bags (HTS 3923.21.00.85) • ITC reports official imports stats for 2005 only. • Import quantities were approx. 239 million lbs. in ’05 ($15 per 1,000 unit). • Imports were valued at $ 108 million. *Ranked by import volumes Source – ITC Trade Database
Non Re-closable PE Bags – HTS 3923.21.00.90 Import Values Import Quantities 1,000 units $ Million $ 799 M 105 $ 658 M 90 $ 490 M 55 Lbs. 1.6 B 1.4 B 822 M Conversion Factor – 15 lbs per 1,000 units Source – U.S. Official Trade Stats, ITC Trade Database
Non Re-closable PE BagsTop 5 Import Sources - 2005 • It appears that PE bags in this category were re-classified under • HTS 3923.21.00.85. • Re-classification makes it difficult to • analyze trends because all imports from supplying countries decreased in 2005. *Ranked by import volumes Source – ITC Trade Database
Re-closable PE Bags – HTS 3923.21.00.19 Import Values Import Quantities 1,000 units 44.8 $ Million $ 169 34.6 30.2 $126 $ 106 Lbs. 454 M 519 M 672 M Conversion Factor – 15 lbs per 1,000 units Source – U.S. Official Trade Stats, ITC Trade Database
Re-closable PE BagsTop 5 Import Sources - 2005 • Imports from China and Thailand • accounted for a substantial portion of total imports in 2005 – 62%. • Chilean imports rose by 33% from levels in 2004, surpassing Canadian • import quantities. • Although relatively small in terms of absolute amounts, imports from South American and Central America appear to be growing: Brazil (90.4%), Dom. Rep. (3,369%), Colombia (240%), Argentina (511%). *Ranked by import volumes Source – ITC Trade Database
Questions/Issues • Do the HTS categories for PE bags reflect business reality? • Are they adequate to accurately monitor/track bag imports? • Would the industry benefit from more specific break-downs? • If so, where are the “clear dividing” lines?
WHAT CAN SPI/FBF DO? • Consider whether to pursue more specific categories • Advocacy before ITC and Customs • Form Task Force • Need input of knowledgeable industry participants • Assistance of experienced customs attorney
Recent Trade Developments • China Currency Manipulation • China trade legislation • U.S.-Korea FTA • U.S.-Malaysia FTA