5/2/2018 USITC - MTBPS MTBPS: Comment 933 Miscellaneous Tariff Bill Petition (MTBP) Temporarily suspend the duty on certain Men's or boys' man-made woven sleepwear separates Comment Id: 933 Date of Submission: February 23, 2017 1:37:03 PM EST Petition Id: 1839 Date of Submission: December 8, 2016 3:23:56 PM EST (1) Commenter Information (1) Let's get started. Please enter the commenter information. Commenter Entity/Individual Commenter Name: National Council of Textile Organizations Commenter Address: 1701 K St NW Suite 625 Washington DC 20006 Commenter Contact Contact Information: Todd Ethington Senior Gov Affairs Manager 2028228027 (2) Independent Rep. Information (2) Are you an independent representative? No The Commission recognizes that a company may retain outside assistance to submit a comment (e.g. a lawyer or consultant). (3) Commenter Type (3) Commenter Type Trade Association or Group https://mtbps.usitc.gov/external/comments/comment/933.html 1/3 5/2/2018 USITC - MTBPS MTBPS: Comment 933 (4) Comment Information (4) Comment Reason: Object to the request Comment Text: On behalf of the U.S. textile industry, including the hundreds of thousands of American workers in the domestic fiber, yarn, and fabric manufacturing sector, the National Council of Textile Organizations (NCTO) objects to MTB petition number 1839. This petition is for a finished product, not a manufacturing input, and should not be considered for duty relief under the American Manufacturing Competitiveness Act (AMCA), PL 114-159. Our objection is based on three main concerns. First, finished products like those in this petition are fully processed, ready to go directly to consumers with no further processing or manufacturing required. These imported products do not require any U.S. inputs or manufacturing activity at any step of production, and do not meet the stated intention of the AMCA “to remove the competitive disadvantage to United States manufacturers and consumers and to promote the competitiveness of United States manufacturers…” (Sec. 2 [b]). Next, granting reduced or suspended duty status to finished goods through the MTB process directly impacts U.S. manufacturers of that or a competitive product’s component parts. U.S. textile manufacturers produce numerous inputs for a wide range of textile and apparel products. Finished products like those in this petition are “like or directly competitive with” products produced in the U.S. or in U.S. free trade agreement (FTA) partner countries from U.S.-manufactured textile inputs (AMCA, Sec. 7[4] and [5]). Finally, utilizing the MTB to benefit finished products undermines the current U.S. FTA structure and breaks faith with our FTA partners. Under virtually all U.S. FTAs, lucrative tariff benefits are granted only when the production of inputs and final assembly of finished textiles and apparel occur within the FTA region per the yarn-forward rule. Using MTBs for end-products does not incentivize investment in U.S. or FTA regional manufacturing. Further, using MTBs for finished goods gives non-FTA countries all the benefits of access to U.S. consumers without any of the vital concessions normally agreed to in exchange, like reciprocal market access, IP protection, enhanced labor and environmental standards, and others. For these reasons, NCTO believes that including this product in an MTB package approved by Congress would undermine U.S. manufacturing output and employment. We appreciate the ITC’s careful and complete consideration of this objection. Please contact NCTO for further information. I claim that the information supplied above in the Comment Text textbox is confidential business information, as defined in 19 CFR 201.6(a). No https://mtbps.usitc.gov/external/comments/comment/933.html 2/3 5/2/2018 https://mtbps.usitc.gov/external/comments/comment/933.html USITC - MTBPS MTBPS: Comment 933 3/3