NCTO Files Public Comments on Proposed Section 301 Tariffs

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WASHINGTON, DC — The National Council of Textile Organizations (NCTO) filed public comments on the Trump administration’s proposed Section 301 tariffs on $200 billion in imports from China on September 6.  The submission is below.


The Honorable Robert E. Lighthizer
United States Trade Representative
600 17th Street, NW
Washington, DC 20508

Via Online Submission at / Docket No. USTR-2018-0026 – Section 301

Re: Request for Comments Concerning Proposed Modification of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation (83 FR 33608)


Dear Ambassador Lighthizer:

The National Council of Textile Organizations (NCTO) appreciates the opportunity to provide public comments regarding the above-referenced Federal Register notice found at 83 FR 33608, dated July 17, 2018 (Docket USTR-2018-0026).  The following information is provided in addition to NCTO’s August 20 testimony as part of Panel 6 at the Section 301 Committee’s public hearing, which is attached for reference.

To summarize, while NCTO remains highly supportive of the overarching case against China’s intellectual property abuses, we continue to encourage USTR and the Section 301 Committee to prioritize the following products in our sector:

•          finished apparel that tracks with product being sourced from U.S. Free Trade Agreement (FTA) partners,

•          textile-based home furnishings and other end items, and

•          advanced technical textile products. 

The subject $200 billion list largely incorporates intermediate textile manufacturing inputs that undergo further processing as opposed to finished products where there would be a benefit throughout the U.S. textile and apparel supply chain of retaliatory tariffs against China.  In certain instances, there is a clear domestic supply of the inputs on the subject 301 list, but, in other cases, such as with respect to rayon and acrylic staple fibers, U.S. manufacturers utilizing these inputs are dependent on imports.  The 301 list also incorporates many dyes, chemicals and finishes used in the textile manufacturing process and additional types textile machinery that would raise production costs and undermine U.S. competitiveness. 

Along with these comments, NCTO has submitted detailed supplementary information to USTR and strongly encouraged our member companies to be active participants in the public comment process in commenting directly as to the impact on their businesses. 

Thank you for the opportunity to provide continued input in the Section 301 process.



Augustine Tantillo
President & CEO

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