The US apparel sector's recommendation comes in response to a comment sought by the USTR for the 2026 National Trade Estimate (NTE) Report on Foreign Trade Barriers.
AAFA trade and transportation specialist Audrey Clark, who submitted the comment on behalf of the association, calls for a non-stacking model, that is similar to Japan and the EU.
Clark also pushed for the removal of tariffs on manufacturing inputs and machinery and for tariffs on free-trade-agreement (FTA) qualifying products to be eliminated.
In addition, Clark said that any new measures should be phased in with sufficient lead time for enforcement agencies and supply chains to adapt.
“We believe these reforms, paired with the administration’s strong enforcement posture, will help ensure a more resilient, fair, and forward-looking trade environment for the US apparel and footwear industry,” Clark stated.
In her submission, Clark identified several existing tariff programmes that create uncertainty for sourcing and planning.
These include Section 301 tariffs on China and proposed Section 301 tariffs on Nicaragua, proposed Section 232 tariffs on personal protective equipment and travel goods treated as derivatives of steel and aluminium, and tariffs applied under the International Emergency Economic Powers Act (IEEPA) both globally and with additional targeting of China, Canada, Mexico, India, and Brazil.
The submission highlighted the sector’s reliance on trade. AAFA stated that roughly 97% of clothes and shoes bought in the US are imported and that about 95% of consumers who buy clothes and shoes live outside US borders.
The trade group said barriers such as tariffs, quotas, standards and local requirements raise costs, reduce sales, cause delays, and lead to job losses.
According to AAFA, an estimated 70–75% of the value of US imported apparel reflects US value added through design, marketing, compliance, logistics, and retail.
The association said the figure is likely comparable for footwear and travel goods and estimated approximately 3.6m US apparel and footwear jobs in 2025 that depend on those value chains.
The submission also drew attention to domestic tariff policy, reporting 2024 trade-weighted average tariff rates of 14.9% for knit apparel, 14.29% for woven apparel, 12.25% for footwear, 8.7% for home textiles, and 13.85% for travel goods, compared with an overall average trade-weighted tariff rate of about 2.35% in 2024.
AAFA said duties collected on imports of apparel, footwear, textiles and travel goods surpassed $18.3bn in 2024 and that the industry represented about 4.78% of all US imports by value while accounting for 25.70% of all duties collected by Customs.
AAFA said it will continue to gather information from members on barriers affecting exports and provide that information to USTR and other agencies for consideration.
