2016 Letters and Comments
12.13.16 - Multi-organization Letter Expressing Concern on Border Adjustment Tax
AAFA joined with 80 other associations and companies in expressing concern to the House Ways and Means Committee over the border adjustment tax provisions in a proposed series of changes to the corporate tax code. The letter also expresses support for comprehensive tax reform.
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12.07.16 - AAFA Urges FMC to Reign In Excessive Demurrage Fees
AAFA and 24 other organizations petitioned the Federal Maritime Commission (FMC) to use the FMC's existing authority to establish a policy to prevent ocean carriers and terminal operators from charging shippers unreasonable and excessive demurrage fees for situations beyond the shipper's control - such as extreme weather, port strikes/slowdowns, and ocean carrier bankruptcies.
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11.29.16- Industry Letter to EPA on Implementation of the Lautenberg Chemical Safety Act
On November 29, AAFA signed onto a joint letter to the Environmental Protection Agency (EPA) Administrator Gina McCarthy in conjunction with the American Alliance for Innovation (AAI). The letter outlines several areas the group would like EPA to evaluate regarding the Agency's efforts to implement the Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA).
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11.16.16 - Letter Urging Fish & Wildlife Service to Address Serious Concerns with ACE Pilot
AAFA joined the overall business community in urging the U.S. Fish and Wildlife Service (FWS) to address serious concerns regarding the ongoing FWS pilot program for the Automated Commercial Environment (ACE).
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11.01.16 - AAFA Submits Post-Hearing Comments to USTR on GSP Travel Goods Review
AAFA submitted detailed post-hearing comments, following an October 18 hearing at which AAFA testified to ask that all GSP beneficiary developing countries be designated for duty free import of travel goods under the GSP program.
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11.01.16 - AAFA Joins Multi-Association Letter on GSP Travel Goods
AAFA organized a multi-association letter with 12 trade associations to urge the USTR to designate travel goods as duty free from all GSP beneficiary developing countries. The letter was submitted as part of a hearing as which AAFA testified.
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10.27.16 - AAFA Submits Comments on Foreign Trade Carriers to USTR
AAFA submitted comments on foreign trade barriers to the Office of the U.S. Trade Representative in preparation for the annual National Trade Estimates (NTE) report.
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10.26.16 – AAFA, Along with 17 Organizations, Reiterates Request to List Alibaba as a Notorious Market
AAFA and 17 additional industry organizations submitted a letter to the Office of the United States Trade Representative (USTR) reiterating a shared request to have Alibaba listed as a notorious market.
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10.21.16 – AAFA Submits Notorious Markets Rebuttal Comments on Alibaba
AAFA submitted comments to the U.S. Trade Representative (USTR) in response to a filing by Alibaba in connection with the 2016 Notorious Markets Report.
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10.18.16 - testimony by Rick Helfenbein in Support of Extending GSP for Travel Goods
Testimony by Rick Helfenbein, AAFA President and CEO, at the U.S. government's hearing on whether to allow duty-free access for U.S. imports of travel goods (handbags, backpacks, luggage, etc.) under the Generalized System of Preferences (GSP) program for all GSP-eligible developing countries. AAFA strongly supports the addition of ALL travel goods items from ALL GSP beneficiary countries.
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10.18.16- Joint Association Letter to CPSC on Voluntary Remedial Actions and Guidelines for Voluntary Recall Notices and Disclosure Under Section 6(b)
On October 18, AAFA along with nearly four dozen trade associations sent a letter to the U.S. Consumer Product Safety Commission (CPSC) in opposition to the Commission's announcement to resume consideration of the final rules on Voluntary Remedial Actions and Guidelines for Voluntary Recall Notices and Disclosure Under Section 6(b) of the Consumer Product Safety Act.
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10.07.16 - AAFA Sends Letter to Debate Moderator Chris Wallace on UNICOR
AAFA sent a letter to the moderator of the third 2016 Presidential debates - Chris Wallace - encouraging him to ask questions about UNICOR and the damaging impact prison factories have on USA manufacturing.
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10.07.16 - AAFA Sends Letter to Debate Moderator Anderson Cooper on UNICOR
AAFA sent a letter to the moderator of the second 2016 Presidential debates - Anderson Cooper - encouraging him to ask questions about UNICOR and the damaging impact prison factories have on USA manufacturing.
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10.07.16 - AAFA Sends Letter to Debate Moderator Martha Raddatz on UNICOR
AAFA sent a letter to the moderator of the second 2016 Presidential debates - Martha Raddatz - encouraging her to ask questions about UNICOR and the damaging impact prison factories have on USA manufacturing.
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10.07.16 - AAFA Submits Comments on Notorious Markets
AAFA submitted comments to the USTR on notorious markets in connection with USTR's 2016 Out of Cycle review. The comments identify Alibaba, and its ecommerce platforms, including Taobao, as well as more than 100 other physical and online markets.
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10.04.16 - AAFA Submits Comments and Request to Testify on GSP Travel Goods Hearing
AAFA submitted preliminary comments and a request to testify at an upcoming hearing regarding the designation of travel goods to the GSP trade program.
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09.26.16 - AAFA Sends Letter to Debate Moderator Lester Holt on UNICOR
AAFA sent a letter to the moderator of the first 2016 Presidential debates - Lester Holt - encouraging him to ask questions about UNICOR and the damaging impact prison factories have on USA manufacturing.
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09.20.16 - AAFA Urges Government to Take Action on Hanjin Shipping
AAFA joined 120 other organizations from a broad swath of the U.S. business and agricultural community in urging the U.S. government to step up their efforts to help resolve the Hanjin Shipping situation because of the significant adverse impact on the U.S. apparel and footwear industry.
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09.13.16- AAFA Comments on Ontario's Upholstered and Stuffed Articles (USA) Regulation
AAFA submitted comments in response to the proposal on Ontario's Upholstered and Stuffed Articles Regulation.
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09.08.16 - Joint Letter to Senate in Support of TPP
AAFA joined with a coalition of 117 other associations, companies, and brands in support of the Trans-Pacific Partnership (TPP) in a letter sent to each House member. The letter was timed to coincide with Back to School season.
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09.08.16 - Joint Letter to House in Support of TPP
AAFA joined with a coalition of 117 other associations, companies, and brands in support of the Trans-Pacific Partnership (TPP) in a letter sent to each House member. The letter was timed to coincide with Back to School season.
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09.02.16 - Joint Association Letter on AGOA
AAFA signed on to a multi-association letter in connection with the 2016 review of the African Growth and Opportunity Act (AGOA), with special focus on Lesotho and used clothing trade issues.
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08.16.16 - AAFA Submitted Comments to the USITC in Conjunction with the Miscellaneous Tariff Bill Process
AAFA submitted comments to the U.S. International Trade Commission (USITC) on the miscellaneous tariff bill process that the USITC is creating in response to the American Manufacturing Competitiveness Act (AMCA), which moved the MTB review process from Congress to the USITC.
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08.11.16 - AAFA Supports Ratification of Trade Facilitation Agreement by Non-FTA Partners
AAFA joined a coalition of about 30 other trade associations in urging non-Free Trade Agreement partners (such as Angola) to quickly ratify and implement the Trade Facilitation Agreement (TFA). When implemented, the TFA, which reduces cross border delays, will expand merchandise exports by more than $1 trillion and create 20 million trade-based jobs.
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08.11.16 - AAFA Supports Ratification of Trade Facilitation Agreement by FTA Partners
AAFA joined a coalition of about 30 other trade associations in urging Free Trade Agreement partners (such as Chile) to quickly ratify and implement the Trade Facilitation Agreement (TFA). When implemented, the TFA, which limits cross border delays, will expand merchandise exports by more than $1 trillion and create 20 million trade-based jobs.
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08.10.16 - Letter to Gary Johnson on UNICOR/Federal Prison Industries and Made in USA
AAFA sent a letter to Gary Johnson (and other Presidential candidates) urging him to make commitments, if elected President, to eliminate UNICOR/Federal Prison Industries' mandatory source status and prohibit UNICOR/Federal Prison Industries from competing as a small business.
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08.10.16 - Letter to Donald Trump on UNICOR/Federal Prison Industries and Made in USA
AAFA sent a letter to Donald Trump (and other Presidential candidates) urging him to make commitments, if elected President, to eliminate UNICOR/Federal Prison Industries' mandatory source status and prohibit UNICOR/Federal Prison Industries from competing as a small business.
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08.10.16 - Letter to Jill Stein on UNICOR/Federal Prison Industries and Made in USA
AAFA sent a letter to Jill Stein (and other Presidential candidates) urging her to make commitments, if elected President, to eliminate UNICOR/Federal Prison Industries' mandatory source status and prohibit UNICOR/Federal Prison Industries from competing as a small business.
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08.10.16 - Letter to Hillary Clinton on UNICOR/Federal Prison Industries and Made in USA
AAFA sent a letter to Hillary Clinton (and other Presidential candidates) urging her to make commitments, if elected President, to eliminate UNICOR/Federal Prison Industries' mandatory source status and prohibit UNICOR/Federal Prison Industries from competing as a small business.
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08.08.16 - Multi-Association Letter Urging Early Renewal of West Coast Port Contract
AAFA signed on to a letter with more than 110 other associations urging the International Longshore and Warehouse Union and the Pacific Maritime Association to begin early discussions so that a contract extension or new long-term contract can be put in place well before the current contract expires.
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08.04.16 - Industry Letter to President Obama on GSP Travel Goods
AAFA joined with more than 100 other companies, brands, and associations in urging President Obama to designate all 28 travel goods categories for all GSP beneficiary countries.
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07.29.16 - AAFA Sends Uzbek Cotton Letter to World Bank
AAFA joined dozens of other stakeholders in urging the World Bank to establish benchmarks the Uzbek government must meet in prevent the use of government-sanctioned and government-orchestrated forced labor in Uzbekistan's annual cotton harvest. The World Bank should require that the benchmarks be met in order for World Bank loans to Uzbekistan to continue.
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07.26.16 - AAFA Supports Trade Facilitation Legislation
AAFA joined dozens of other organizations in expressing strong support for the Global Gateways Trade Capacity Act (S. 2201). This important legislation that will enhance our competitiveness, bring significant development benefits to the developing world, and more effectively direct trade capacity assistance.
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07.08.16 - AAFA Urges T-TIP Negotiators to Open Port Dredging Contracts to European Companies
AAFA joined other associations in urging U.S. negotiators to open U.S. port dredging contracts to European companies as part of the U.S./European Transatlantic Trade & Investment Partnership (T-TIP) Free Trade Agreement. Such a provision would accelerate the ability of East and Gulf Coast Ports to handle the larger ships now moving through the expanded Panama Canal.
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07.05.16 - AAFA Urges U.S. Government to Approve Travel Goods for All GSP Countries
AAFA joined with three other associations in urging the U.S. government to review its recent decision and instead immediately make travel goods duty free for ALL GSP-eligible countries.
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06.30.16 - AAFA Applauds Downgrade of Uzbekistan in Human Trafficking Report
AAFA applauded the U.S. government for downgrading Uzbekistan to Tier 3, the lowest level possible, in the publication of the 2016 annual Trafficking in Persons (J-TIP) report. The U.S. government downgraded Uzbekistan because of the continued use of government-sanctioned and government-orchestrated forced labor in Uzbekistan's cotton fields.
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06.20.16 - AAFA Ltr to DHS on 100% Scanning Mandate
AAFA joined over 100 business organizations in sending a letter to Department of Homeland Security (DEH) Secretary Jeh Johnson urging DHS to abandon efforts to find a way to meet Congress' 100% scanning mandate and instead explain to Congress the strong risk-based targeting system DHS has put in place and request that Congress rescind the 100% scanning mandate.
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06.15.16 - AAFA Opposes "Pink Tax" Legislation
AAFA joined other retail-based industries in strongly opposing SB899, the so-called California “pink tax” legislation.
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06.08.16 - Joint Footwear Statement on Trans-Atlantic Trade and Investment Partnership (T-TIP)
The American Apparel & Footwear Association (AAFA), the European Confederation of the Footwear Industry (CEC), and Footwear Distributors and Retailers of America (FDRA) issued a joint statement urging US and EU negotiations to conclude provisions in the Trans-Atlantic Trade and Investment Partnership (T-TIP) that are commercially meaningful for the footwear industry, such as duty elimination, flexible rules of origin, and regulatory harmonization.
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06.08.16 - Multi Association Letter Supporting Berry Clarification in Defense Bill
AAFA joined a coalition of associations and unions supporting an amendment to clarify the application of Berry to certain subcontracts in the Senate version of the FY 2017 National Defense Authorization Act (NDAA).
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06.07.16 - Multi Association Letter Opposing Effort to Weaken Berry Athletic Footwear Provision
AAFA led a coalition of nearly twenty other associations and organizations in opposing an effort to strip a provision from the Senate version of the FY 2017 National Defense Authorization Act (NDAA) that would clarify the application of the Berry amendment to athletic footwear.
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06.01.16- Comments to CPSC on Opportunities for Regulatory Coherence between the U.S. and EU
The American Apparel & Footwear Association (AAFA), submitted comments on the Consumer Product Safety Commission's budget priorities for fiscal years 2017 and 2018, recommending the Commission dedicate resources toward international harmonization of product safety standards.
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05.24.16- AAFA Letter in Support of H.R. 2576, the TSCA Modernization Act of 2015
AAFA sent a letter to the U.S. House of Representatives in support of H.R. 2576, the TSCA Modernization Act of 2015.
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05.24.16- AAFA Key Vote “Yes” to H.R. 2576 – the TSCA Modernization Act of 2015
AAFA sent a letter to the U.S. House of Representatives in support of H.R. 2576, the TSCA Modernization Act of 2015.
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05.23.16 - Multi Association Letter Expressing Concerns over Youth Sports Concussion Act
AAFA joined a coalition of associations expressing support for the goals but concerns over the wide scope of the Youth Sports Concussion Act (HR 4460) .
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05.17.16- AAFA Comments on Possible Restriction of Hazardous Substances (CMR 1A and 1B) in Textile Articles and Clothing for Consumer Use under Article 68(2) of Regulation EC No 1907/2006 (REACH)
The American Apparel & Footwear Association (AAFA), submitted comments in response to the proposal to restrict CMR 1A and 1B substances in textile articles and clothing under Article 68(2) of Regulation EC No 1907/2006 (REACH).
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05.16.16 - AAFA-Led Letter Opposing Efforts to Strip out Berry Athletic Footwear Provisions from House NDAA
AAFA led 18 organizations in sending a letter urging the House to reject an amendment that would strip AAFA-supported language in the House version of the FY 2017 National Defense Authorization Act (NDAA) the would require the Department of Defense (DoD) to comply with the Berry Amendment as it pertains to DoD purchases of athletic footwear.
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05.12.16 - AAFA Urges Congress to Require Sales under the Foreign Military Sales (FMS) Program to be Berry-Compliant
AAFA joined with the Warrior Protection & Readiness Coalition (WPRC) in a letter to the Senate Armed Services Committee (SASC) expressing support for provisions to ensure clothing and footwear procured by the U.S. military and sold under the Foreign Military Sales (FMS) program, which uses U.S. taxpayer money to purchase certain articles for foreign militaries, comply with the Berry Amendment.
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05.10.16 - Letter Urging Senate to Maintain Current Trucker Hours of Service (HOS) Rules
AAFA joined a coalition of business groups in sending a letter urging Senate appropriators to include language in the FY 2017 T-HUD appropriations bill to retain the current 34-hour restart for truckers.
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05.10.16 - AAFA Urges Inclusion of Berry Athletic Footwear Provision in NDAA
AAFA sent a letter to the Senate Armed Services Committee urging them to include a provision in its version of the FY 2017 National Defense Authorization Act (NDAA) requiring the Department of Defense (DoD) to comply with the Berry Amendment as it pertains to DoD purchases of athletic footwear.
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05.03.16- Multi Association Letter to CPSC on Change of GCC Enforcement Policy
On May 3, AAFA in addition to other industry stakeholders sent a letter to the Consumer Product Safety Commission (CPSC) commending the Commission's decision to eliminate the need to file General Conformity Certificates (GCCs) for adult clothing exempt from testing.
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04.28.16 - Letter to USITC on Dominican Republic Earned Import Allowance Program
AAFA sent a letter to the U.S. International Trade Commission (USITC) making observations and recommendations on the operations of the Earned Import Allowance Program, which is part of the U.S./Central American-Dominican Republic Free Trade Agreement (CAFTA-DR).
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4.28.16- Trade – AAFA Participates in the Transatlantic Trade & Investment Partnership (TTIP) Stakeholders Forum
AAFA participated in the Stakeholders Forum in New York City on April 28, during the 13th round of negotiations between the United States and European Union (EU) towards the Transatlantic Trade & Investment Partnership (TTIP) Free Trade Agreement.
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04.26.16 - AAFA Key Vote Letter to House on Miscellaneous Tariff Bills (MTBS)
AAFA sent a key vote letter to the House urging support for the American Manufacturing Competitiveness Act of 2016 (HR 4923) to renew the miscellaneous tariff bill (MTB) process.
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04.26.16 Multi association letter in support of Berry Amendment provision
AAFA joined with other trade associations in urging the House Armed Services Committee to approve an amendment - offered by Representatives Jones, Hunter, and Tsongas - to delete an increase in the simplified acquisition threshold (SAT) in the FY 2017 National Defense Authorization Act (NDAA).
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04.25.16 - AAFA Urges U.S. Government to Downgrade Uzbekistan in Trafficking in Persons Report
AAFA urged the U.S. government to downgrade Uzbekistan in its next annual Trafficking in Persons (J-TIP) report because of the continued government-sanctioned and government-orchestrated use of forced labor in Uzbekistan's cotton fields.
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04.25.16 - Letter to Representatives Tsongas and Poliquin on Athletic sneaker berry legislation
AAFA sent a letter to Representatives Tsongas and Poliquin expressing support for their legislation - Stepping Up for American Workers and Troops Act (HR 4935) - to clarify that the Berry Amendment applies to athletic sneakers, which are currently distributed through a voucher program that avoids Berry compliance.
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04.25.16 - AAFA Letter in Support of Tsongas Amendment on athletic Footwear
AAFA sent a letter to the leadership of the House Armed Services Committee (HASC) urging for legislation offered by Representatives Tsongas and Poliquin clarifying that athletic shoes are required to comply with the Berry Amendment.
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04.20.16 - Coalition Letter Urging Congress to Approve New MTB Process
AAFA joined a wide swath of the U.S. business community in urging Congress to apprvoe the “American Manufacturing Competitiveness Act of 2016” (H.R. 4923 and S. 2794), legislation that would establish a new miscellaneous tariff bill (MTB) process to temporarily reduce or eliminate unnecessary taxes on imported inputs and products not available domestically.
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03.25.16 - Multi-Association and Company Letter in Support of GSP Travel Goods Designation
AAFA led a coalition of more than 100 associations, companies, and brands in urging USTR to approve petitions to add certain travel goods to the GSP program.
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03.15.2016- Multi-Association Coalition Urges Vermont to Address Critical Issues in Draft Chemical Guidance
On March 15, AAFA along with other industry groups sent comments to the Vermont Department of Health regarding Vermont's Chemical Disclosure Program Guidance for manufacturers. The comments highlight concerns that the regulation is burdensome or inconsistent, particularly when other states have acted more consistently when addressing the same issues.
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03.18.16 - AAFA Tells Congress What it Wants to See in CPSC's FY 2017 Budget
AAFA joined a broad swath of industry stakeholders in sending a letter to Congress regarding the U.S. Consumer Product Safety Commission's (CPSC) fiscal year (FY) 2017 budget request. The letter urges Congress to use the appropriations process to ensure that the CPSC fulfills its critical safety mission, without unduly burdening business.
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03.15.16 - AAFA Urges Sides to Start West Coast Port Labor Contract Negotiations ASAP
AAFA joined over 100 other industry groups in urging organizations representing the port employers and the dock workers to start now on negotiations to extend the current West Coast ports labor contract or strike a new contract. The current West Coast port labor contract expires June 30, 2019.
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02.29.16- Multi-association Coalition Sends Letter Urging Congressional Consensus on TSCA Reform Legislation
On February 29, AAFA along with other industry groups sent a letter to the U.S. House and Senate Committees with jurisdiction over reform of the Toxic Substance Control Act (TSCA) urging a thoughtful approach to reconciling differences between the House and Senate version of the legislation. The bipartisan supported legislation will reform the nation's chemical management framework law and strengthen the Environmental Protection Agency's authority to regulate chemicals in commerce.
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02.10.16 - AAFA Submits Pre-Hearing Brief to USTR on Travel Goods
AAFA (on its one behalf and on behalf of the Travel Goods Association and the Fashion Accessories Shippers Association) submits a pre-hearing brief to the USTR in connection with the March 4, 2016 hearing to review petitions to add most travel goods to the GSP program. The pre-hearing brief outlines why all accepted travel goods petitions should be approved for all GSP beneficiary countries.
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02.29.16 - Multi-Association Coalition Submits Letter to USITC on Travel Goods
AAFA joined a coalition of nearly two dozen trade associations urging the acceptance of all pending travel goods petitions for the GSP program.
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02.29.16 - AAFA Files Post Hearing Comments to USITC on Travel Goods
Following oral comments, AAFA (on its own behalf and on behalf of the Travel Goods Association and the Fashion Accessories Shippers Association) files post hearing comments to the U.S. International Trade Commission (USITC) urging acceptance of all pending travel goods petitions for the GSP program.
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02.05.16 - AAFA Files Comments on Operation of Free Trade Agreements
AAFA filed comments to the U.S. International Trade Commission (USITC) evaluating the operation of U.S. free trade agreements (FTAs).
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02.05.16 - AAFA Files Special 301 Comments
AAFA submitted comments to the USTR identifying and evaluating foreign intellectual property rights practices and activities.
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02.03.16 - AAFA Files Pre-Hearing Comments on Adding Travel Goods to the GSP
AAFA (along with the Travel Goods Association and the Fashion Accessories Shippers Association) filed comments to the U.S. International Trade Commission in preparation for a February 24 hearing to support duty free status for certain travel goods under the Generalized System of Preferences (GSP) program.
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01.30.16 - AAFA Urges U.S. Government to Downgrade Uzbekistan in Trafficking Report
AAFA joined dozens of other organizations in urging the U.S. government to downgrade Uzbekistan to the lowest level (Tier 3) in the U.S. government's upcoming Trafficking in Persons (J-TIP) report in response to Uzbekistan's continued use of government-sanctioned and government-orchestrated forced labor in Uzbekistan's cotton fields during the fall 2015 cotton harvest.
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01.28.16 - AAFA Testifies at U.S. Government Africa Hearing
AAFA testified at a U.S. government hearing to discuss trade policies in Africa for the next ten years. The hearing was scheduled approximately six months after AAFA pushed legislation through in Congress to renew the African Growth and Opportunity Act (AGOA) through 2025. In its testimony, AAFA outlined how the next decade affords Africa an opportunity to develop a vertical, responsible, and competitive industry.
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1.25.16- AAFA Opposes Proposed Changes to California Prop 65 Warning Labels
AAFA as a part of a coalition of two hundred California-based and national organizations submitted comments to the Office of Environmental Health Hazard Assessment's (“OEHHA”) on the agency's Notice of Proposed Rulemaking to Article 6- Clear and Reasonable.
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1.15.16 - AAFA Urges Senate to Pass Customs Legislation
AAFA joined over a dozen other organizations in calling on the Senate to immediately approve long-pending Customs legislation.
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1.14.16 - AAFA Urges U.S. Government to Adopt Specific Port Metrics
AAFA joined over 100 other organizations in urging the U.S. Department of Transportation to adopt specific port metrics that would provide timely, useful, accurate, and comparative data on the day-to-day operations of America's ports.
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1.14.16- AAFA Testifies Before New York Council on Proposed Chemical Management Law
On January 14, AAFA testified before the New York City Council on proposed legislation to prohibit the sale and distribution of children's products in New York City containing more than the specified amounts of formaldehyde, benzene, lead, mercury, antimony, arsenic, cadmium, and cobalt.
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01.13.16 - AAFA Submits Comments to USTR on Employment Impact of TPP
AAFA submitted comments to the Office of the U.S. Trade Representative (USTR) on the potential employment impacts on the apparel, footwear, and travel goods industry of the Trans-Pacific Partnership (TPP) Free Trade Agreement.
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01.13.16 - AAFA Submits Pre-Hearing Testimony to USITC on TPP
AAFA submitted pre-hearing testimony to the U.S. International Trade Commission on the potential employment impacts on the apparel, footwear, and travel goods industry of the Trans-Pacific Partnership (TPP) Free Trade Agreement.
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