2025 fourth_quarter Filing

Trade Domestic/Foreign (TRD) Discussions with Congress and Administration (including USTR, Treasury, Commerce, ITC, Labor, State, Agriculture, DLA, and Customs) on the following items: o Proposed and implemented tariffs under IEEPA, Section 301, and Section 232. o Bilateral China trade issues, including WTO compliance and the Section 301 investigation and Section 232 investigations. o Western Hemisphere issues, including USMCA, CAFTA-DR, and Haiti. o Implementation of existing and negotiation of new free trade agreements (FTAs). Issues discussed include: -Rules of origin -Duties -Customs provisions -IPR provisions -Labor provisions -Regulatory harmonization -Transportation measures -Government procurement. -Port maintenance issues -Trade deficits and global value chains. Tariffs and proposed bills to regulate tariff policy, including: U.S. HTS Chapter 62 U.S. Note 2 - water resistant definition [H.R.960] o New and existing trade preference programs, including: AGOA Extension Act (H.R.6500) Haiti Economic Lift Program Extension Act (H.R.6504) Haiti Economic Lift Program Extension Act of 2025 (S.742) Comments and Testimony to USTR on the USMCA Review Discussions with Congress, USTR, CBP, State, and Commerce on the Agreements on Reciprocal Trade o Various trade and customs initiatives (such as First Sale, 9802, de minimis, 321/FTZs, duty drawback, single window/ITDS, changes to ACE, green trade preferences for sustainable materials, and pending classifications, rulings, and regulations) covering textiles, apparel, footwear, and travel goods. o Foreign trade barriers and practices (including comments for annual NTE and Special 301 and notorious markets reports). o Pending nominations. o Current and proposed sanctions, including: - North Korea sanctions (CAATSA). - Uyghur Forced Labor Prevention Act (Public Law No: 117-78). o Country of Origin Labeling Online Act Discussions with Congress and CBP on Customs Modernization. Discussions with Congress, CPSC, and FTC to allow Digital Labeling for clothes. Discussions with Congress on the Americas Act Discussions with Congress, USTR, Commerce, CBP on 321 de minimis Discussions with Congress and Federal Communications Commission (FCC) on NextNavs petition for rulemaking to reorganize the 902-928 MHz band Discussions with USTR on Section 301 Nicaraguas acts, policies, and practices related to labor rights, human rights, and the rule of law. H.R. 1968 - FY 2025 Continuing Resolution, through September 30, 2025 S.J.Res. 77 - End Canada Tariffs S.J.Res. 81 - End Brazil Tariffs S.J.Res. 88 - Terminate Global Tariffs S. 1272/H.R. 2665 - Trade Review Act of 2025 S.1241/H.R.2548 - Sanctioning Russia Act of 2025 Discussions with Congress, CBP, USTR, State, Commerce, Treasury, and the White House on Executive Order 14257 of April 2, 2025 (Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits) Defense (DEF) Comments and discussions on Berry Amendment, Federal Prison Industries (FPI), and Ability One programs with Administration and Members of Congress. Discussions with Members of Congress, White House, DoD, USTR, TSA, and DHS about implementation of Berry and procurement issues and the following legislation: FY 2026 Defense related measures - - HR 4016/S. 2572 - FY 2026 DoD Appropriations - HR 3838/S. 2296/S. 1071 - FY 2026 National Defense Authorization Act - S. 2199/HR 4159 - BOOTS Act - HR 5371 - FY 2026 Continuing Resolution Discussions with Congress and Administration on government procurement provisions in trade agreements. Discussion with Administration on follow up to the DLA War Games, including use of DPA Title III; stockpiling; centralized procurement of textiles, apparel, and footwear under DLA; and elimination of small purchase threshold. Discussions with the Administration and Congress on economic price adjustments (EPAs) in contracts. Discussions with the Administration and Congress on government procurement of PPE products. Discussion on textile, apparel, and footwear supply chain war game. Discussion with Congress and Administration on measures to strengthen the textile, apparel, and footwear supply chain including provisions relating to procurements of home textiles, boots, and other uniforms in a manner consistent with Berry. Discussions with the Administration and Congress on restrictions of per and polyfluoroalkyl substances (PFAS). Discussion with the Administration and Congress on tariff and immigration issues related to the Defense Industrial Base. Small Business Discussions with Congress and Administration impact of tariffs and logistics issues on small business. Discussions with Federal Trade Commission (FTC) on digitizing apparel labels as well as on textile, wool, fur, and care labeling rules, and other labeling rules, including Made in USA labeling. Discussions with the Administration and Congress on FPI reform and impact on small business. Environment Discussions with Congress and Administration on issues as it relates to textile recycling infrastructure and technology, federal approaches to extended producer responsibility, material sustainability, climate, and environment Discussions with Congress on funding for textile circularity infrastructure Discussions with Congress on H.R.960 - Protect Our Clothes from PFAS Act Discussions with Congress, on trade incentives for preferred material usage, and non-tariff barriers to utilizing recycled materials Discussions with Congress, EPA, and FTC to allow Digital Labeling for clothes Discussions with Congress and FTC on environmental marketing claims and the FTCs Green Guides Labor Discussion of WRAP program and with various legislative branch and executive branch officials. Discussions with Congress and Administration (including Labor, State, USTR, USAID, DFC, and CBP) to ensure effective implementation of and action on: o Child/Forced labor rules and lists, o Uzbek cotton, o ILO Better Work programs, o China Xinjiang o Bangladesh, Burma (Myanmar), Cambodia, Ethiopia, Guatemala, India, Jordan, Mauritius, Sri Lanka, Taiwan, Central America, Haiti, and FTA and trade preference labor cases. o Implementation of the Uyghur Forced Labor Prevention Act (Public Law No: 117-78). o Funding for various U.S. government agencies and international organizations that work on labor rights and leveling the playing field for American businesses and workers. o Discussion with administration officials at USTR and DOL/ILAB on the labor provisions in the bilateral agreements on reciprocal trade (ARTs) o Discussion with administration officials at State, USTR, DOL/ILAB on funding for ILAB and the International Labor Organization (ILO) Product Safety (CSP) Discussions with Administration, including CPSC, Commerce, USTR, and EPA, and various Congressional offices on: Final e-Filing regulations and CPSCs 2016 enforcement discretion policy for adult apparel Implementation of Consumer Product Safety Improvement Act (CPSIA) Common standards and risk information sharing with trading partners Regulations involving flammability, sleepwear, and drawstring hazards. Regulations involving Per- and polyfluoroalkyl substances (PFAS), including TSCA Section 8e reporting requirements, and proposed PFAS restrictions by the European Union and EU Member States. Possible modifications to flammability requirements to add spandex to the exempt fibers list. Implementation of previously implemented legislation to reduce third party testing burdens and costs. Monitoring issues relating to apparel, footwear, and travel goods/fashion accessories safety and product labeling. Implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act Foreign chemical management initiatives that function as non-tariff barriers. Link between counterfeit products, restricted chemicals, and how they hamper sustainability efforts Digitization of apparel labeling as it relates to product safety information and recalls. Regulation of Infant Support Cushions as it relates to head support products. Transportation Discussions with Congress and Administration on shipping delays and costs from the Red Sea crisis Discussions with Congress on freedom of navigation in Red Sea and Indo-Pacific including the South China Sea and Taiwan Strait Discussions with Congress on protecting arctic shipping routes Discussions with Congress and Administration on West Coast port, Canada port, and East Coast port labor contract negotiations Discussions with Congress and Administration on Hours of Service (HoS) and other driver-related rules. Discussions with Congress and key agencies on port metrics. Discussions with Congress and the administration on rail issues Discussions with Congress and the administration on trucking issues Discussions with Federal Maritime Commission (FMC) and Congress on shipping delays, ocean carrier / port terminal issues, including congestion surcharges, demurrage charges, anti-trust issues, and PierPass. Discussions with Congress and the Administration on comprehensive infrastructure funding and repair. Specifically on relief funding for Key Bridge Specific legislation on key transportation issues impacting the industry: o SHIPS for America Act - in opposition of fees and restrictions o Ocean Shipping Reform Act (Public Law No: 117-146) - in support of o Truck Parking Safety Improvement Act (H.R. 2367) - in support of o Surface Transportation Reauthorization Act - preliminary discussions while text is being drafted, no formal position taken US Trade Representative Section 301 Investigation into Chinas Maritime Logistics and Shipbuilding Sectors - in opposition of port fees, equipment tariffs, and restrictions IPR Discussions with Congress and Administration on: nominations,appointments and/or funding, including an Under Secretary of Commerce for Intellectual Property and Director of the U.S. Patent and Trademark Office (USPTO), the Commissioner for U.S. Customs and Border Protection, the Intellectual Property (IP) Attache Program , and more. o Intellectual property, and counterfeit practices across the digital devalue chain of counterfeits, including e-commerce, social commerce, social platforms, and product and consumer safety. o Dangers of the growth of fraudulent advertising across social media platforms and fraudulent websites; discussions around curbing fraud, and pre-verification of paid advertising o Related international policies o Artificial Intelligence o Consumer safety and product safety o Trademark Modernization Act of 2020 o Fraudulent trademark filings at the USPTO and abroad. o USTR and others in the inter-agency process re Special 301 Report and Notorious Markets Report List o Dupe influencers across social media. o National Security related to illicit economies State Dept, USPTO, IPEC, IPRC re OECD / guidelines for countering illicit trade in counterfeit goods on online marketplaces o Reforms around customs and border protection procedures and anti-counterfeiting processes; updates related to what is needed by brands to identify counterfeits o Counterfeits, gray market goods and resale. o Consumer awareness campaign re the dangers of counterfeits. o Dangers of counterfeits and product safety dangers for consumers to U.S. businesses, workers and jobs. o Legislation and/or regulations to create secondary liability structure for online platforms. o Implementation, enforcement, and any technical corrections needed for INFORM Consumers Act (Public Law No. 117-328) o Reintroduction of the SHOP SAFE Act (S.2934) (HR 8684) o Expansion of S.2531 - SOCIAL MEDIA Act o Raising awareness and exploring solutions for the Digital Devalue Chain of Counterfeits o Information sharing; S.2677 (and H.R. 4930) introduced by Sens. Grassley (R-IA) and Hassan (D-N.H.) to authorize Customs and Border Protection (CBP) to clarify and expand CBPs authority to share key IP-related information with rights holders and other relevant stakeholders. and CBP technology donation program o The Communications Decency Act of 1996 Proposal to Sunset Section 230