The American Apparel & Footwear Association (AAFA) has included certain Amazon marketplaces in its submission to the Office of the United States Trade Representative (USTR) identifying foreign markets that facilitate the sale of counterfeits.

The submission was part of USTR's 2018 Special 301 Out-of-Cycle Review of Notorious Markets, which identifies foreign physical and online marketplaces that reportedly engage in and facilitate substantial copyright piracy and trademark counterfeiting.

The AAFA identified Amazon UK, Amazon Canada, and Amazon Germany in its submission.

"Identifying the sale of counterfeit products is crucial to our ongoing efforts to defend American intellectual property, American jobs, and American consumers," says Rick Helfenbein, president and CEO of the AAFA. "The annual review of notorious markets by the Office of the United States Trade Representative is essential in this process."

The AAFA says its focus is on marketplaces that put its members at a "significant disadvantage" by selling a substantial amount of counterfeit goods that may not meet safety regulations and contribute to damaging intellectual property.

"While we are always willing to work with companies to improve protection efforts, we also think it is important that consumers are made aware of current problems. Additionally, we think it is reasonable to expect leading e-commerce giants to commit to safeguarding American intellectual property. Counterfeiters continue to develop new ways to sell their illegal goods and we hope that the companies listed in our submission will be vigilant in their efforts to prevent illicit activities taking place on their platforms.

"Amazon has been a leader of, and has made valuable contributions to, the future of retail. We believe Amazon can, and should, be a leader in the fight against counterfeits.

In addition to submitting the comments, the AAFA also raised concerns over the Administration's continued use of what it says are punitive tariffs on legitimate goods imported to the US.

"While these tariffs have been imposed to counter intellectual property theft and forced technology transfer, we believe the tariffs will instead incentivise the sale of counterfeit products, as they will not be charged this added tax."