Free Trade Area of the Americas - FTAA

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Public
FTAA.soc/civ/54
June 22, 2002

Original: English

FTAA - COMMITTEE OF GOVERNMENT REPRESENTATIVES ON THE PARTICIPATION OF
CIVIL SOCIETY

COVER SHEET FOR OPEN INVITATION CONTRIBUTIONS


Name(s) Stephen Lamar
Organization(s) American Apparel & Footwear Association
Country USA


Chair of the Committee of
Government Representatives on the
Participation of Civil Society
C/o Secretaria del Area de Libre Comercio de Las Americas (ALCA)
Apartado Postal 89-10044
Zona 9, Ciudad de Panama
Republica de Panama

Via Email: soc@ftaa-alca.com

RE: COMMENTS BY AMERICAN APPAREL & FOOTWEAR ASSOCIATION (AAFA)  ON THE FREE TRADE AREA OF THE AMERICAS (FTAA)

On behalf of the American Apparel & Footwear Association - the U.S. national trade association of the apparel and footwear industries - I am writing to offer comments on the Free Trade Area of the Americas (FTAA).

We are especially pleased that the Civil Society Committee is undertaking this on-going request for public comments. This action creates an important precedent of transparency that should help demystify the trade negotiating process and remove some of the anxiety felt by those who fear trade liberalization.

We wish to offer the following observations, which closely track many points we have made in previous submissions through this process and the U.S. Trade Representative’s Office regarding the FTAA.

Government Procurement: As with the WTO Agreement on Government Procurement, the appropriate annex should note that the United States retains the right to require that clothing and textiles produced for the U.S. Defense Department be made in the United States entirely of U.S. inputs. This tracks an important national security principle that has been a central component of U.S. procurement law for more than half a century and which was recently re-endorsed by the U.S. Congress.

Market Access: In addition to balanced liberalization on tariffs, the final agreement should require all countries to prohibit or terminate fees and other special assessments that are imposed on imports. Likewise, the agreement should prohibit reference pricing or customs valuation practices that serve to discriminate against imports. Finally, the final FTAA agreement should explicitly provide docking provisions for those goods that are currently afforded duty free entry under the Caribbean Basin Trade Partnership Act (CBTPA), and a possible Andean Trade Preference Act expansion. Because those programs expire once the FTAA takes effect, it is imperative that the benefits conferred by these provisions be captured in a seamless manner by the FTAA such that companies operating under those programs not experience gaps in market access.

Rules of Origin: We are dismayed to see that some countries are still contemplating special rules of origin on textiles and apparel (Chapters 50 through 63). As noted in previous statements, AAFA strongly supports the approach taken in Breaux Cardin, which is consistent with the single tariff shift approach that confers origin based on assembly. AAFA does not endorse the NAFTA rule of origin in apparel for the FTAA. Likewise on footwear, AAFA supports the tariff shift approach and does not favor extension of the NAFTA rule to the FTAA (particularly regarding the prohibition of unformed uppers).

Safeguards: The FTAA should have strict limitations both on the thresholds that must be triggered before they can be used, as well as on the duration and ability to be extended. Safeguards should sunset automatically unless the complaining party can affirmatively prove the continuation of the injury.

Customs Procedures: Customs operations, including documentation requirements, should reflect practices of the trade. Companies should not be required to keep or file paperwork that is now kept in electronic format or which is no longer generated for legitimate commercial reasons. Extraneous paperwork provides logistical obstacles and costs that can greatly undermine the gains associated with the FTAA. At the same time, we strongly favor harmonization of customs operations to encourage the border free environment - within the hemisphere - that is a key goal of the FTAA.

Intellectual Property Rights: The sanctity of trademarks is critical to the health of apparel and footwear brands. AAFA favors strong protections for trademarks as part of a comprehensive IPR monitoring and enforcement regime.

Labeling Harmonization: As in the NAFTA, AAFA favors the development of a harmonized labeling scheme to bring the different countries care, origin, ID, and fiber content labeling practices for garments and footwear (with respect to origin) into a single standard.

Social Responsibility: AAFA members strive to ensure that their products are produced under legal, ethical, and humane conditions. AAFA itself has endorsed the Worldwide Responsible Apparel Production (WRAP) program, which contains 12 principles that are monitored through an independent factory inspection program. More than a dozen other organizations in this hemisphere have endorsed this program as well. These principles reflect and promote fair labor, anti-narcotics, security, environment, and anti-transshipment goals. More information on this program can be found at www.wrapapparel.org.

AAFA appreciates the opportunity to submit these comments. Because of the fast pace of these negotiations and the short timeframe for solicitation of comments, we reserve the right to offer additional comments as new issues are raised. Please contact me on ------------ if you have any questions.

Sincerely,

 

Stephen Lamar
Senior Vice President
 

 
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