July 7, 2026

The Honorable Jamieson Greer
United States Trade Representative
600 17th Street NW
Washington, DC 20508

Re: Comments Concerning Proposed Action in Section 301 Investigations of Various Economies Related to the Failure to Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced with Forced Labor (Docket No. USTR-2026-0265)

Dear Ambassador Greer:

American Circular Textiles appreciates the opportunity to submit comments regarding the proposed actions in the Section 301 investigations concerning the failure of various economies to impose and effectively enforce prohibitions on the importation of goods produced with forced labor.

American Circular Textiles strongly supports the Administration’s efforts to eliminate forced labor from global supply chains. Forced labor has no place in the textile and apparel industry, and strong enforcement is essential to protecting workers, promoting fair competition, and strengthening responsible manufacturing.

American Circular Textiles supports the proposal submitted by the National Council of Textile Organizations (NCTO), the American Apparel & Footwear Association (AAFA), the United States Fashion Industry Association (USFIA), and the U.S. Industrial Fabrics Institute (USIFI). We believe the proposed textile trade incentive program is an important opportunity to strengthen U.S. manufacturing, expand Western Hemisphere supply chains, and reduce dependence on higher-risk sourcing regions.

Our comments are intended to complement the coalition’s proposal by recommending that any qualifying textile incentive also recognize circular manufacturing inputs and infrastructure, ensuring the next generation of textile manufacturing includes reuse, recycled fibers, secondary raw materials, and the systems needed to recover, repair, remanufacture, and recycle textiles throughout North America.

Recommendation 1: Recognize Circular Manufacturing Inputs

The coalition proposal appropriately incentivizes demand for U.S.-made yarns and fabrics. We encourage USTR to expand eligibility to recognize recycled textile materials, recovered textile materials, and secondary raw materials processed within the United States, USMCA countries, and CAFTA-DR countries as qualifying regional inputs where appropriate.

These materials are increasingly important manufacturing inputs and support investment in domestic textile recovery, sorting, repair, remanufacturing, recycling, and recycled fiber production. Recognizing these materials alongside traditional textile inputs would strengthen regional manufacturing and increase exports while reducing dependence on higher-risk supply chains.

Recommendation 2: Support the Responsible Movement of Circular Materials

The next generation of textile trade policy should support not only the movement of finished products, but also the movement of manufacturing materials throughout trusted regional supply chains.

American Circular Textiles encourages USTR to ensure that future textile incentives facilitate the responsible movement of recovered textile materials, including finished product destined for reuse and textile recycling, recycled textile fibers, and other secondary raw materials among USMCA and CAFTA-DR partners for reuse, repair, remanufacturing, and recycling.

We also encourage USTR to distinguish legitimate consumer-to-consumer imports of previously owned goods from newly manufactured commercial imports and apply special tariffs to these previously owned finished goods. Consumer-to-consumer resale trade extends product life, reduces waste, supports small American resale businesses, and provides households affordable options without increasing foreign manufacturing demand. Any future policy should reinforce through special tariff treatment the efficient movement of bona fide consumer-owned secondhand goods while maintaining strong enforcement against forced labor, fraud, and commercial circumvention.

Recommendation 3: Support Investment in Circular Manufacturing Capacity

Building domestic textile recycling capacity will require access to specialized sorting and other remanufacturing processing equipment. Much of this equipment is currently manufactured outside the United States.

American Circular Textiles encourages USTR to consider appropriate treatment for specialized recycling equipment that is not yet commercially available from domestic manufacturers while continuing to encourage long-term U.S. manufacturing of these technologies.

As USTR evaluates future textile incentives, we also encourage consideration of the robust employment opportunity associated with textile collection, sorting, repair, reuse, remanufacturing, recycling, and recycled fiber production alongside traditional textile manufacturing. American Circular Textiles has prepared an illustrative employment analysis, attached as Annex A, demonstrating the potential scale of this opportunity.

Conclusion

American Circular Textiles believes the coalition’s proposal provides a strong foundation for strengthening U.S. textile manufacturing and Western Hemisphere supply chains.

Incorporating the recommendations above would help ensure that future textile incentives support the full textile manufacturing value chain—from virgin materials to recycled materials—and position the United States to compete in the next generation of textile manufacturing.

We appreciate the opportunity to provide these comments and welcome the opportunity to work with USTR as these proposals continue to develop.

Respectfully submitted,
American Circular Textiles

Annex A

Illustrative Employment Opportunity Associated with Circular Textile Infrastructure

The following analysis was prepared by American Circular Textiles to illustrate the potential order of magnitude of domestic employment associated with increased textile recovery and reuse. It is not intended as a forecast or economic impact study. Rather, it applies a published employment factor from an existing state-level study to publicly available EPA estimates of U.S. textile disposal to demonstrate the potential scale of opportunity associated with expanded circular textile infrastructure.

*Illustrative estimates prepared by American Circular Textiles by applying a published employment factor from the California Textiles Study to EPA estimates of U.S. textile disposal. These figures are intended to demonstrate potential order of magnitude rather than predict actual employment outcomes.

The estimates above reflect reuse-related employment only and do not quantify additional employment associated with collection, sorting, repair, resale, reverse logistics, remanufacturing, fiber-to-fiber recycling, recycled fiber production, equipment manufacturing, technology development, or related manufacturing activities.

References

• U.S. Environmental Protection Agency. Advancing Sustainable Materials Management: Textiles Material-Specific Data.

• Garson & Shaw. California Textiles Study.