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Sunday, September 14, 2025

Liquidated Damages Claims, Other Textile Enforcement Measures ... - Sandler, Travis & Rosenberg, PA

U.S. Customs and Border Protection saw increases in some measures of its efforts to enforce trade laws and regulations governing textiles in fiscal year 2023, including particularly large increases in liquidated damages claims, commercial fraud penalties, and cargo exams. However, CBP also saw decreases in Section 301 tariffs collected, seizures, and audits.

For more information on trade-related issues affecting textiles and apparel, please contact textile and apparel practice leader Elise Shibles at (415) 490-1403 or via email.

Textile and apparel goods have some of the highest import duty rates in the U.S. and may also be subject to Section 301 additional tariffs if imported from China. Schemes designed to circumvent these tariffs include false invoicing, false marking and labeling, false claims of origin, illegal transshipment, misdescription, undervaluation, false declarations of the right to make entry, false trade preference claims, and smuggling.

Textile and apparel goods are thus a top priority for CBP enforcement efforts. The charts below highlight trends in these efforts over the previous quarter and the past year.

...

4Q 2023

3Q 2023

4Q 2022

Section 301 duties collected

$697 million

$624 million

$953 million

Forced labor e-allegations

6

9

n/a

Factory visits

33

24

25

% factories discrepant

24

40

64

Non-IPR seizure number

174

149

379

Non-IPR seizure value

$3.7 million

$5.9 million

$6.99 million



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