American Circular Textiles Urges USTR to Include Circular Manufacturing in Textile Trade Incentive Program
Group calls for recognition of recycled fibers, secondhand goods, and domestic recycling infrastructure in forced labor enforcement proposal
WASHINGTON, D.C. — July 9, 2026 — American Circular Textiles (AMCIRC) today submitted formal comments to the Office of the U.S. Trade Representative (USTR), urging the agency to incorporate circular manufacturing into a proposed textile trade incentive program tied to Section 301 investigations on forced labor enforcement (Docket No. USTR-2026-0265).
The comments support a coalition proposal for a textile trade incentive program 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). American Circular Textiles's filing recommends the program go further by recognizing reuse, recycled fibers, and the infrastructure needed to recover, repair, remanufacture, and recycle textiles across North America. The inclusion of these supply chain elements is a critical step toward strengthening U.S. manufacturing, expanding Western Hemisphere supply chains, and reducing dependence on higher-risk sourcing regions.
"We firmly back the Administration's push to root out forced labor in global supply chains," says Rachel Kibbe, Founder & CEO of AMCIRC. "Forced labor has no place in textiles or apparel, and rigorous enforcement across all textile supply chains. Supporting circular textile supply chains in the U.S. and in the Western Hemisphere plays a critical role in safeguarding workers, ensuring fair competition, and building a more responsible manufacturing sector."
Key recommendations from American Circular Textiles's comments:
Recognize circular manufacturing inputs: The coalition proposal encourages demand for U.S.-made yarns and fabrics, and AMCIRC recommends that scope be widened. Specifically, it asks USTR to count recycled textile materials, recovered textile materials, and other secondary raw materials processed in the U.S., USMCA, and CAFTA-DR countries as qualifying regional inputs. These materials already support growing investment in domestic textile recovery, sorting, repair, and recycling. Recognizing them alongside traditional inputs would strengthen regional manufacturing, boost exports, and reduce dependence on higher-risk supply chains.
Support responsible movement of circular materials: AMCIRC argues that future textile trade policy should support the movement of manufacturing materials, not just finished products, across trusted regional supply chains. It asks USTR to facilitate the responsible cross-border movement of recovered textiles, including finished products destined for reuse and recycling, recycled fibers, and other secondary raw materials among USMCA and CAFTA-DR partners for reuse, repair, and recycling. At the same time, AMCIRC suggests that USTR clearly separate legitimate consumer-to-consumer resale of used goods from newly manufactured commercial imports, applying special tariff treatment to the former. This resale trade extends product life, reduces waste, and supports small American resale businesses, and any new policy should protect it while still enforcing strong safeguards against forced labor and fraud.
Support investment in circular manufacturing capacity: Scaling up domestic textile recycling requires specialized sorting and processing equipment, much of which isn't yet made in the United States. AMCIRC urges USTR to give appropriate consideration to this equipment while it's still sourced from abroad, while encouraging U.S. manufacturers to eventually build it domestically. It also asks USTR to weigh the substantial job creation potential of collection, sorting, repair, remanufacturing, and recycling alongside traditional textile manufacturing. To support this point, AMCIRC also shared an illustrative employment analysis showing the potential scale of jobs tied to expanded circular textile infrastructure.
AMCIRC's comments also include an illustrative analysis estimating that diverting textiles from U.S. landfills for reuse alone could support significant domestic employment — ranging from an estimated 9,600 jobs at a 10% diversion rate to approximately 48,000 jobs at a 50% diversion rate. Substantial additional jobs would be created with the inclusion of repair and care, sorting, recycling, collection, remanufacturing, and other necessary employment categories across the circular textile spectrum.
The coalition proposal provides a strong foundation for strengthening U.S. textile manufacturing and Western Hemisphere supply chains — but AMCIRC believes it will fall short of its full potential unless it also accounts for circular materials, responsible cross-border movement of recovered goods, and investment in recycling infrastructure. AMCIRC urges USTR to incorporate these recommendations as the proposal moves forward, positioning U.S. textile manufacturing to compete for the next generation of the industry — from virgin materials to recycled fiber.
See the full letter here. To stay updated on the developments of this proposal or learn more about how to become a member of AMCIRC, visit our website www.americancirculartextiles.com or subscribe to our newsletter.
ABOUT AMERICAN CIRCULAR TEXTILES (AMCIRC)
American Circular Textiles (AMCIRC) is a U.S.-based coalition of leading companies working to advance circular textile policy, infrastructure, and market development. AMCIRC convenes stakeholders across retail, resale, recycling, repair, manufacturing, and technology to support the growth of domestic circular textile systems and strengthen U.S. competitiveness in the evolving global textile economy.
MEDIA CONTACT: press@americancirculartextiles.com
