The request was submitted last week (9 July 2026) as part of formal comments relating to a proposed programme arising from Section 301 investigations into forced labour practices.
The organisation’s submission supports a coalition proposal presented earlier last week by the National Council of Textile Organisations, the American Apparel & Footwear Association, the United States Fashion Industry Association, and the US Industrial Fabrics Institute.
While acknowledging the foundation laid by the coalition’s proposal, AMCIRC argues that including circular materials, easing the responsible movement of recovered goods, and supporting recycling infrastructure are essential to achieve the programme’s objectives.
In its comments, the organisation urged the USTR to go further by including reuse, recycled fibres, and the infrastructure necessary for textile recovery, repair, remanufacture, and recycling within the programme’s scope.
AMCIRC founder and CEO Rachel Kibbe said: “We firmly back the Administration's push to root out forced labour in global supply chains. Forced labour has no place in textiles or apparel, and rigorous enforcement across all textile supply chains. Supporting circular textile supply chains in the US and in the Western Hemisphere plays a critical role in safeguarding workers, ensuring fair competition, and building a more responsible manufacturing sector.”
The AMCIRC argues that recognising inputs such as recycled and recovered textile materials from the US, USMCA, and CAFTA-DR countries as regional inputs would align with growing investments in textile recovery and recycling.
The document suggests that qualifying these materials alongside conventional inputs may strengthen regional manufacturing capabilities, improve export volumes, and lessen reliance on sourcing from regions considered higher risk.
It also recommends that future textile trade policy facilitate the cross-border movement of both manufacturing materials and finished products for reuse and recycling.
The organisation requests that the USTR support the responsible transfer of recovered textiles, recycled fibres, and secondary raw materials among trusted trade partners in the USMCA and CAFTA-DR regions. It also calls for distinguishing legitimate resale of used goods by consumers from newly manufactured imports, recommending favourable tariff treatment for the former.
Regarding manufacturing capacity, AMCIRC highlights the need for investment in specialised sorting and processing equipment, much of which currently needs to be sourced from outside the US.
The US-based coalition urges the USTR to allow for continued import of these technologies while encouraging domestic manufacturing in the future.
Furthermore, the organisation projected that if textiles were diverted from US landfills for reuse, this could support notable job creation domestically, estimating around 9,600 jobs at a 10% diversion rate and up to roughly 48,000 jobs at a 50% diversion rate.
Further roles would be generated by incorporating activities such as repair, care, sorting, recycling, collection, and remanufacturing across the circular textile sector, it stated.
