2014 Letters and Comments

12.23.14 - Multi Association Letter on West Coast Port Congestion

AAFA joined more than 100 other associations in a joint letter to President Obama expressing concerns over on-going West Coast Port Congestion and urging his involvement.

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12.17.14 - AAFA Letter to Chinese Vice Premier Urging Conclusion of US/China Bilateral Investment Treaty

With U.S. apparel and footwear companies increasingly entering the Chinese market, AAFA joined over a dozen other business organizations in sending a letter to Chinese Vice Premier Wang Yang urging China to quickly conclude a Bilateral Investment Treaty (BIT) with the United States. The letter was sent on the eve of the 25th meeting of the U.S./China Joint Commission on Commerce and Trade (JCCT) in Chicago.

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12.10.14 - AAFA Key Vote Letter to Senate on Government Funding Measure (HR 83)

AAFA issued a Key Vote letter to the Senate on HR 83, Consolidated and Further Continuing Appropriations Act, 2015.

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12.10.14 - AAFA Key Vote Letter to House on Government Funding Measure (HR 83)

AAFA issued a Key Vote letter to the House on HR 83, Consolidated and Further Continuing Appropriations Act, 2015.

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12.08.14 - AAFA Comments to CBP on Information Requirement

AAFA submitted comments expressing concern over a new Customs and Border Protection (CBP) proposal imposing new information requirements on the trade.

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11.19.14 - AAFA Key Vote letter on H.R. 4012- the Secret Science Reform Act of 2014

The American Apparel & Footwear Association (AAFA) issued a key vote letter for HR 4012, the Secret Science Reform Act of 2014.

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11.18.14 - AAFA AAFA Urges Congress to Pass Tax Extenders Legislation ASAP

AAFA joined a group of over 500 organizations in sending letters urging Congress to extend tax provisions crucial to U.S. businesses during its current Lame Duck session.

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11.17.14 - AAFA Pushes Congress to Pass GSP Renewal

AAFA joined a list of 621 companies and trade associations in sending a letter November 17 to U.S. House and Senate leadership urging for the retroactive renewal of the Generalized System of Preferences (GSP) program during the Lame Duck session.

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11.17.14 - AAFA Submits Multi-Association Letter to OEHHA on Potential Regulatory Action on Proposition 65 (Prop 65)

On November 17, the AAFA in addition to nearly one hundred forty California- based and national organizations, and businesses submitted joint comments to California’s Office of Environmental Health Hazard Assessment’s (OEHHA) request for public participation on potential regulatory action on Proposition 65 (Prop 65).

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11.12.14 - AAFA Urges Congress to Approve E-Fairness Legislation During the Lame-Duck

AAFA joined a coalition of industry associations and individual companies in sending a November 12 letter urging House Speaker John Boehner to take immediate action to pass legislation that will create equality between how brick-and-mortar businesses and internet sellers are taxed on their sales.

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11.07.14 - AAFA Signs Multi-Association Letter on Proposed Changes to Prop 65 Warning Labels

AAFA on November 7, signed on to a multi-association letter to California's Office of Health Hazard Assessment (OEHHA) regarding the proposed amendment to California’s Prop 65 regulations requiring businesses to list 12 specific chemicals on warning labels.

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11.06.14 - Multi-Association Industry Statement on TPP

AAFA issued a statement with 12 other associations representing textile, apparel, and retail sectors in the United States, Australia, Canada, Malaysia, Singapore, and Vietnam regarding apparel provisions in the TPP. The statement urges support for meaningful market access and flexibility in the rules for the apparel industry and Customs provisions that facilitate compliant trade.

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10.31.14 - AAFA Multi Association Letter to CPSC on Proposed 1110 Rule

AAFA signed on to multi-association letter, requesting the CPSC to establish a stakeholder advisory group as the CPSC considers changes to the import process.

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10.31.14 - Comments to the CPSC on Electronic Filings of Certificate of Compliance

AAFA submitted comments to the U.S. Consumer Product Safety Commission (CPSC) on the proposed rule regarding electronic filings of certificates of compliance.

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10.30.14 - AAFA Calls Upon Federal Maritime Commission For Immediate Action to Address Rampant Port Congestion

AAFA sent a letter October 30 to Federal Maritime Commission Chairman Mario Cordero expressing the industry's urgent concerns with untenable congestion present in the Ports of L.A. and Long Beach. AAFA urged the FMC to address these issues in part by allowing a congestion discussion agreement between the Ports, working with the Ports on solutions to unjust demurrage charges, and encouraging a swift resolution of the ILWU/PMA negotiations.

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10.30.14 - AAFA Calls Upon L.A./Long Beach for Immediate Action to Address Rampant Port Congestion

As part of its fight against port congestion, AAFA sent a letter to the Ports of Los Angeles and Long Beach, expressing the industry's urgent concerns with rampant congestion in this a major North American gateway for consumer product imports. The letter also went to their terminal operators, as well as the Mayors of L.A. and Long Beach, AAFA urged quick solutions to chassis shortages and unavoidable demurrage charges levied against its members.

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10.29.14 - Comments to USTR on National Trade Estimate Report on Foreign Trade Barriers

AAFA submitted comments to the United States Trade Representative in response to the request for public comments to compile the 2015 National Trade Estimate (NTE) Report on Foreign Trade Barriers.

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10.24.14 - aafa submits comments identifying notorious markets

AAFA submitted comments identifying notorious markets - online and physical marketplaces that engage in or facilitate substantial copyright piracy and trademark counterfeiting - for the annual notorious market report.

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10.21.14 - Comments to DTSC on Safer Consumer Products Draft Priority Product Work Plan

AAFA submitted comments to California's Department of Toxic Substances Control on the Safer Consumer Products Draft Priority Product Work Plan.

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10.20.14 - AAFA Joins 101 U.S. Industry Associations Urging Speedy Agreement on Contract for West Coast Dockworkers

AAFA joined with 101 other U.S. industry associations in a letter on October 20 to the Pacific Maritime Association (PMA) and International Longshore & Warehouse Union (ILWU) urging a speedy agreement for a contract covering West Coast dockworkers. ILWU labor is currently working under an expired contract, and solutions for rampant port congestion will be difficult to implement without a ratified contract.​

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10.10.14 - AAFA Comments in Support of Innovation Manufacturing Institute

AAFA submitted comments to the Department of Defense in support of creating a fiber and textile specific Institute for Manufacturing Innovation (IMI). The IMI would be an opportunity to expand current work on near-shoring and re-shoring the fiber and textile innovation, and improve technological capabilities of the industry.

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10.01.14 - Presentation on TTIP

AAFA and USFIA presented at the stakeholder forum on the Transatlantic Trade and Investment Partnership in regards to apparel and footwear and discussed recommendations.

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09.30.14 - Joint Position Paper on T-TIP

AAFA joined with the European Branded Clothing Alliance (EBCA) and the U.S. Fashion Industry Association (USFIA) in issuing a joint position paper for the Trans-Atlantic Trade and Investment Partnership (T-TIP) Free Trade Agreement.

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09.15.14 - AAFA Urges Congress to Confirm Holleyman as Deputy USTR Before Adjourning for November Elections

AAFA sent a letter to the leadership of the U.S. Senate urging the Senate to confirm former Business Software Alliance (BSA) CEO Robert W. Holleyman II as the next Deputy U.S. Trade Representative (USTR) before Congress adjourns at the end of this week for the November elections. AAFA urged Senate leaders to take swift action to approve Holleyman as negotiations on key free trade agreements and other important trade issues are entering a critical juncture.

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09.08.14 - AAFA/Others Outline Priorities on First Day of Annual Uzbek Cotton Harvest

AAFA joined with dozens of other stakeholders in issuing a statement marking the first day of the annual fall cotton harvest in Uzbekistan. The statement outlines the specific demands of AAFA and the other groups as work continues to end the Uzbek government-sanctioned and Uzbek government-organized use of forced labor and forced child labor in the annual cotton harvest.

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09.02.14 - AAFA Urges U.S. Government to Drop Section 337 Patent Infringement Case on Certain Jeans

AAFA joined with the other apparel/retails associations in submitting comments strongly urging the U.S. International Trade Commission (ITC) to drop a Section 337 patent infringement case against U.S. importers of certain laser-abraded jeans.

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08.13.14 - Statement by Seven Trade Associations In Support of AGOA Renewal

Multi-association statement by AAFA and six other trade associations in support of renewal of the African Growth and Opportunity Act (AGOA), emphasizing timely renewal, long term renewal, long term extension of 3rd country fabric provisions, and extension of 3rd country fabric provisions to all AGOA beneficiaries.

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08.12.14 - AAFA Stakeholder Uzbek Cotton Letter to U.S. Government

AAFA joined with other stakeholders in sending a letter to Secretary of State John Kerry urging the U.S. government to persuade the ruling regime in Uzbekistan to implement significant changes before this fall’s annual cotton harvest to end the government-sanctioned and government-orchestrated use of forced labor and forced child labor to pick cotton.

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08.04.14 - Comments on Draft Informed Compliance Publication on First Sale

AAFA submitted comments to Customs and Border Protection (CBP) on draft changes to an informed compliance publication on First Sale.

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08.04.14 - Letter to President on AGOA Renewal

AAFA sent a letter to President Barack Obama asking him to work closely with Congress to quickly renew and extend the African Growth and Opportunity Act (AGOA).

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07.24.14 - AAFA Comments Opposing Customs APHIS User Fees

AAFA joined the business community in submitting comments to the U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) urging APHIS to reject proposals that would impose user fees on importers using APHIS at the ports as well as increasing overtime fees for importers.

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07.17.14 - AAFA Urges Congress to Modify Bangladesh Language in Defense Approps Bill

AAFA joined with the rest of the apparel/retail industry in sending a letter urging the heads of the House and Senate Appropriations Committee to modify language included in the Senate-version of the FY 2015 Defense Appropriations bill.

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07.16.14 - AAFA Key Vote Letter in Support of the Blackburn amendment

AAFA expressed strong support for the amendment to H.R. 5016 offered by Rep. Marsha Blackburn (R-TN) that would stop the U.S. Consumer Product Safety Commission (CPSC) from proceeding with a rule that harms the voluntary recall process for consumer products. AAFA has key voted the Blackburn amendment as a YES vote.

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07.02.14 - AAFA Legwear Committee Urges USTR to Consider Sock/Hosiery Concerns within TPP

AAFA sent a letter on behalf of the Legwear Committee to USTR Michael Froman urging the trade agency to consider the U.S. legwear industry’s need for viable rules of origin for socks and hosiery within the Trans-Pacific Partnership (TPP).

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06.30.14 - Multi-Association Letter to USTR on Japan Leather Footwear TRQ

AAFA and 3 other associations representing the entire footwear industry sent a letter to US Trade Representative Ambassador Froman urging the Administration to make elimination of a tariff rate quota that Japan imposes on US footwear be a priority in the Trans Pacific Partnership (TPP).

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06.23.14 - AAFA Urges Congress to Renew Export-Import Bank

AAFA joined 864 other companies and industry associations in sending a letter urging Congress to renew the Export-Import (Ex-Im) Bank. AAFA continues to work with the Ex-Im Bank to provide more financing to support the Western Hemisphere textile and apparel supply chain.

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06.20.14 - AAFA Calls for FMC Guidance on Carrier Congestion Surcharges

AAFA joined with a multi-industry coalition representing U.S. manufacturers, farmers, wholesalers, retailers, distributors, importers, and transportation and logistics providers, in a June 20 letter to the Federal Maritime Commission (FMC) requesting further guidance on the proposed “congestion surcharges” announced by ocean carriers if there are disruptions at West Coast ports as a result of the ongoing labor contract negotiations.

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06.20.14 - AAFA Letter to U.S. Government Applauding Decision on Uzbekistan

AAFA joined with other stakeholders in applauding the U.S. government for keeping Uzbekistan at Tier 3 in the just released 2014 Trafficking in Persons (J-TIP) Report. In the report, the U.S. government found that Uzbekistan continued to use government-sanctioned and government-organized forced labor and forced child labor in the Fall 2013 cotton harvest.

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06.13.14 - AAFA Letters to APHIS on Customs User/Overtime Fees

AAFA joined the business community in sending letters requesting extension of the public comment period on proposals by the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) that would impose user fees on importers using APHIS at the ports as well as increasing overtime fees for importers.

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06.13.14 - Letter to OEHHA on Proposition 65 Warning Label Amendments

The U.S. apparel, footwear, travel goods, and fashion accessories industries, submitted comments to California's Office of Health Hazard Association in opposition to a pre-regulatory proposal to expand Proposition 65 (Prop 65) warnings.

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06.12.14 - AAFA Signs on to Joint Letter to OEHHA in Opposition to Expanding Prop 65 Warning Labels

AAFA signed on to a coalition letter drafted by the California Chamber of Commerce in opposition to OEHHA’s proposal to expand Prop65 warning labels. AAFA supports CalChamber’s argument that OEHHA’s proposal is unworkable for nearly every industry sector across California and the nation.

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06.09.14 - AAFA Calls to Restore Section 179 Small Business Expensing

AAFA on June 2nd joined a coalition of multi-industry organizations in support of legislation that would restore small business expensing (Section 179) and permanently index its level to inflation.

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06.03.14 - letter to the New York State Legislature opposing burdensome proposed chemical regulations (S.4616/A.6328)

AAFA joined several other associations in sending a letter to the New York State Legislature opposing burdensome proposed chemical regulations (S.4616/A.6328).

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06.03.14 - AAFA Calls for Study and 1-Year Suspension of FMCSA Hours of Service 'Restart' Rule

AAFA on June 3 joined a coalition of associations and businesses in calling for the Senate Appropriations Committee and the Subcommittee on Transportation, Housing, and Urban Development (THUD) to move ahead with a proposed study on restrictive Hours of Service rules for truckers that have been in effect since July 2013.

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06.02.14 - Multi-association letter on 100 percent scanning

Letter sent by more than 70 trade associations, including AAFA, to the Secretary of Homeland Security regarding 100 percent scanning.

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06.02.14 - AAFA Letter to CPSC on Revising the Interpretation of Prints

The American Apparel & Footwear Association (AAFA), submitted comments in response to the request for recommendations as it relates to non-statutory ways to reduce the cost of third-party testing in the apparel and footwear industry while ensuring continued compliance with the applicable consumer product safety rules, bans, standards, and regulations.

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05.21.14 - Presentation to TTIP Stakeholders on US/EU Regulatory Coherence

AAFA gave a presentation to the negotiators and stakeholders at the 5th round of discussions for the Trans-Atlantic Trade and Investment Partnership (TTIP) on the need for U.S. & EU regulatory coherence.

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05.21.14 - Joint AAFA-CFDA Letter on Textile Tariffs in T-TIP

AAFA and the Council of Fashion Designers of America sent a joint letter to U.S. Trade Representative (USTR) Ambassador Froman urging elimination of tariffs on textiles in the Trans Atlantic Trade and Investment Partnership (T-TIP).

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05.14.14 - letter to Senate Judiciary Leaders supporting patent reform

AAFA signed an association letter to Senate Judiciary Chairman Leahy and Ranking Member Grassley supporting the Senate's efforts on patent reform and encouraging customer-friendly provisions.

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05.07.14 - Multi Association Letter to CPSC on Proposed User Fees

AAFA signed on to a multi- association letter requesting the U.S. Consumer Product Safety Commission (CPSC) conduct direct stakeholder engagement on the CPSC’s proposal for a new user fee on imported products to pay for the national expansion of the Risk Assessment Methodology (RAM) program.

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05.06.14 - Travel Goods Industry CEOs Call for Passage of GSP UPDATE Act

Senior-level leadership of major U.S. travels goods companies sent a signed coalition letter to Congress on May 6 in support of the GSP UPDATE Act. The legislation would make travel goods (backpacks, purses, handbags, computer cases, luggage, wallets, smartphone cases, etc.) eligible for duty-benefits under the Generalized System of Preferences (GSP) program.

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04.28.14 - Comments to CPSC on Section 6(b) of the CPSA: Information Disclosure

AAFA submitted comments to the Consumer Product Safety Commission (CPSC) regarding the notice of proposed rulemaking (NPR) to update the 16 CFR 1101, that interprets section 6(b) of the Consumer Product Safety Improvement Act.

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04.24.14 - AAFA Ltr Urging U.S. Govt to Keep Uzbekistan at Tier 3 in Trafficking in Persons Report

AAFA joined with the trade associations representing the entire U.S. apparel supply chain – from U.S. manufacturers and U.S. wholesalers to U.S. brands and U.S. retailers – and its 3 million U.S. workers, in urging the U.S. government to again place Uzbekistan in Tier 3 in the 2014 Global Trafficking in Persons Report (J-TIP Report).

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04.11.14 - AAFA Comments on Dominican Republic 2:1 (EIAP) Program

AAFA submitted comments to the U.S. International Trade Commission (USITC) for their annual report to Congress on the operation of the Dominican Republic Earned Import Allowance Program (EIAP), otherwise known as DR 2:1. AAFA reiterated its previous comments that the program, as currently structured, has been a failure, with trade under the program dwindling every year. AAFA urged Congress to fix the program ASAP and made specific recommendations for any fix.

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04.11.14 - Comments to FTC on Care Labeling Roundtable

AAFA submitted comments to the Federal Trade Commission in response to the topics discussed at the Care Labeling Roundtable.

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04.07.14 - AAFA Letter Urging President Obama to Make Elimination of Japan Footwear Quotas a Priority in TPP

In light of his trip to Japan the week of April 7, AAFA sent a letter urging President Barack Obama to make the elimination of Japan’s quota on imports of leather footwear a key priority as the Trans-Pacific Partnership (TPP) enters the final phase of negotiations. Japan’s longstanding leather footwear quotas have effectively prevent U.S.-made and U.S.-branded footwear from entering the huge Japanese footwear market.

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04.07.14 - U.S./Canadian Industry Ltr Urging Elimination of Safety Equipment Duties in Bangladesh

AAFA and the rest of the trade associations representing the U.S. and Canadian apparel and retail industry sent a letter to the Prime Minister of Bangladesh urging the Bangladesh government to immediately eliminate duties on Bangladeshi imports of building and fire safety equipment.

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03.18.14 - Multi-Association Letter on Investment in FTAs

AAFA joined with more than 20 other associations in supporting Bilateral Investment Treaties and the inclusion of investment provisions in Free Trade Agreements.

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03.14.14 - Letter to CPSC Regarding Certificates of Compliance

AAFA Signs on to Joint Association Letter Regarding Certificates of Compliance

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03.14.14 - Letter to Governor of Vermont Peter Shumlin on S 239 Regulating Toxic Substances

AAFA sent a letter to Vermont's Governor, Peter Shumlin, urging him to oppose a bill on regulating toxic substances (S 239). If enacted, this bill would only further complicate the already complex chemical regulatory system, be overly burdensome for many companies, and punishes companies who already have in place high standards when dealing with toxic substances .

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03.13.14 - Letter to Connecticut State Legislators on Newly Proposed Chemical Regulatory Legislation

AAFA signed on to a letter urging Connecticut State Legislators to oppose current chemical regulatory legislation being discussed (HB 5036, HB 5354, and SB 126). These bills, if enacted, would only further complicate the already complex chemical regulatory system and burden companies operating within the Connecticut.

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03.12.14 - AAFA Signs on to Multi-Association Letter in Support of Chemicals in Commerce Act Discussion Draft

AAFA signed on to a multi-trade association letter in support of Congressman John Shimkus’s discussion draft of the Chemicals in Commerce Act (CICA) to reform the Toxic Substances Chemical Act (TSCA.)​

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03.10.14 - Joint AAFA and EURATEX Letter on the TTIP

Just as the fourth round of Trans-Atlantic Trade and Investment Partnership (TTIP) negotiations began in Brussels, the American Apparel & Footwear Association (AAFA) and EURATEX, the trade associations representing the U.S. and European apparel industries, sent the attached letter to Ambassador Froman and Commissioner De Gucht urging both sides to agree to immediate and reciprocal duty-free access for all apparel and textile products in the proposed agreement.

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02.28.14 - AAFA Urges Senate to Confirm Kerlikowske as CBP Commissioner

AAFA joined the business community in urging Senate leaders to schedule a vote as soon as possible on the nomination of Mr. Gil Kerlikowske to be the Commissioner of U.S. Customs and Border Protection (CBP). As the letter notes, “the CBP has been without a Congressionally-approved Commissioner for nearly five years.”

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02.20.14 - Biz Community Ltr on TPP Agreement

AAFA joined more than 40 other trade associations representing a cross section of U.S industry in sending a letter supporting the conclusion of a robust and comprehensive TPP agreement. The letter expresses concern that some countries, including Japan, have not been willing to support full market access in a complete TPP agreement.

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02.18.14 - Letter to Iowa Senate on Formaldehyde Legislation

AAFA joined with others in the business community in sending a letter to the Iowa Senate opposing legislation that would have banned the use of formaldehyde in products intended for children under eighteen years of age, including footwear, apparel, travel goods, and fashion accessories. An Iowa State Senate Committee on February 19 failed to take up SF 2161. With no committee action, the legislation is dead for the year.

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02.04.14- AAFA Comments to the CPSC on Voluntary Recalls NPR

The American Apparel & Footwear Association (AAFA) submitted comments to the Consumer Product Safety Commission’s (CPSC) in response to the notice of proposed rulemaking that would establish standards for voluntary product recalls.

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01.31.14 - Letter to Maine Department of Environmental Protection on Formaldehyde

AAFA joined several other associations in submitting comments to the Maine Department of Environmental Protection on the regulations of formaldehyde in children's products.

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01.30.14 - AAFA Uzbek Cotton Ltr to State on J-TIP Report

AAFA joined a broad coalition of stakeholders in sending a letter urging the State Department to keep Uzbekistan at Tier 3 status in the U.S. government’s upcoming annual Trafficking in Persons (J-TIP) report.

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01.27.14 - AAFA Joins Multi-Industry Coalition Letter to U.S. Senate Urging GSP Renewal

AAFA joined a multi-industry coalition of over 460 companies and associations on January 27 in sending a letter to all members of the U.S. Senate and a letter to all members of the U.S. House of Representatives calling for renewal of the Generalized System of Preferences (GSP) program, which has been expired since July 2013.

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01.27.14 - AAFA Joins Multi-Industry Coalition Letter to U.S. House Urging GSP Renewal

AAFA joined a multi-industry coalition of over 460 companies and associations on January 27 in sending a letter to all members of the U.S. Senate and a letter to all members of the U.S. House of Representatives calling for renewal of the Generalized System of Preferences (GSP) program, which has been expired since July 2013.

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01.15.14 - North American Industry Open Letter on Cambodia Minimum Wage

The six leading North American trade associations representing apparel and footwear brands and retailers sent an open letter to government and industry stakeholders in Cambodia urging an immediate end to the violence and protests regarding Cambodia’s minimum wage.

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01.14.14 - Letter to Congressional Leaders on TPA by Trade Benefits America Coalition

Letter sent by multi-association and company coalition - Trade Benefits America Coalition - in support of the recent introduction of the Trade Promotion Authority renewal legislation.

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01.14.14 - AAFA Testimony before the USITC on AGOA

AAFA’s Steve Lamar delivered testimony before the U.S. International Trade Commission on the African Growth and Opportunity Act.

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01.06.14 - Letter to CPSC regarding Children's Sleepwear Flammability Standards

AAFA received a letter from former CPSC Chairman Inez Tenenbaum that challenged and in some cases misinterpreted our assertions regarding the CPSC's enforcement of the Children's sleepwear standard. Through our rebuttal letter, AAFA is pleased to engage in a constructive dialogue with the CPSC, and looks forward to continuing discussions regarding product safety regulations.

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