CBP Publishes Statistics Showing Aggressive
Enforcement Of Imported Textiles And Apparel

April 13, 2012

On January 19, 2012, CBP published statistics on its website that convincingly show that CBP is stepping up its enforcement of the laws and regulations pertaining to imported textiles and apparel. CBP indicated in its notice that it is giving high priority to this sector (textiles and apparel) due to the fact that there are substantial opportunities for the filing of false entries.

CBP has designated the enforcement of textiles and apparel laws as a Priority Trade Issue (PTI), meaning that substantial resources are devoted to this sector.

The statistics published by CBP clearly show that there are many violations and/or non-compliance in this sector. A complete set of the FY 2011 statistics published by Customs can be found here.

A summary of the FY 2011 statistical data is as follows:

  • No. of Seizures (IPR) involving textiles and apparel:  7,711 valued at $14.47M
  • Commercial Fraud Penalties:  48 valued at $27.32M 
  • Liquidated Damage Assessments Involving Textiles:  746
  • Illegal Transshipments: 165 factories visited in 9 countries; 22% discrepant
  • Trade Preference Claims: 165 factories visited in 9 countries; 27% discrepant
  • Physical Examinations:  Total of 10,444; 1,341 discrepant (13%)
  • Audits:  36 initiated; 40 completed; recommended duty recovery:  $6.499M
  • Laboratory Analyses:  samples tested:  1,363; 654 found discrepant (48%)
  • Special Enforcement Operations:  8 initiated; 7 completed

These statistics clearly reflect the growing trend of CBP to be more vigorous in its efforts to enforce compliance of imported textiles and apparel. In particular, importers of textiles and apparel who use trade preference programs should exercise due diligence to ensure that their imports meet all applicable requirements. 

Companies should carefully consider implementing procedures to ensure compliance with the import requirements relating to their textile and apparel products.

For further information on these procedures or to answer any questions you may have about this or other customs issues, please contact or George R. Tuttle at george.tuttle.sr@tuttlelaw.com; (415) 288-0425.


George Tuttle are attorneys with the Law Offices of George R. Tuttle in San Francisco.


The information in this article is general in nature, and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence, and may not be considered as such.

Copyright © 2012 by Tuttle Law Offices. 

All rights reserved.  Information has been obtained from sources believed to be reliable.  However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.


Subscribe Unsubscribe Feedback Previous Newsletters