Saturday, August 23, 2014

Country of Origin? How About City of Origin?

The Brooklyn Chamber of Commerce has created a "Brooklyn Made" designation available to businesses located in Kings County, NY. 

With the boost in popularity of the "Brooklyn" brand, this marking is in its most simplest form a protectionist measure against non-Brooklyn based companies seeking to capitalize on the borough’s growing popularity.

As discussed in this week's AM New York (photo above), factors for attaining one of the three levels of the "Made in Brooklyn" insignia offered by the Chamber are, not surprisingly, akin to some of those same considerations US Customs looks at when it analyzes country of origin marking and value claims on imported products.  Factors include the amount of raw materials obtained within the territory (i.e. originating materials), level of manufacturing (think: substantial formation) and, the local labor used (i.e., overhead and labor, in value considerations).

More on the Brooklyn Chamber of Commerce can be found here.

As an aside, manufacturing in Brooklyn has been on an upward swing with the neighborhood Sunset Park rapidly emerging as a manufacturing, artist and fashion destination as the waterfront warehouses are being converted into mixed-use spaces that are supporting more than just manufacturing. 

We will be watching closely as the development of this cool Brooklyn neighborhood continues!

Questions/comments?  Post below or email me at

Keep up with me at or:
On Twitter @fashcompliance

Friday, August 22, 2014

Wednesday, July 30, 2014

Washington DC Gets Ready to Discuss AGOA, Textiles From Africa, and More

On Friday August 1, 2014, the Civil Society of the AGOA Forum will be hosting its own two-day meeting under the theme “AGOA:Re-Authorization beyond 2015.”    Time is running out to register but you still can here.

The purpose of this meeting is to come up with written recommendations for presentation to the Ministerial Session of the African Growth and Opportunity Act (AGOA) during the Africa Summit beginning August 5, 2014.

As described by the AGOA Civil Society Network, the AGOA “is a trade mechanism that was passed by the US Government in 2000 to encourage US-Africa trade.   AGOA currently provides the 40 AGOA-eligible countries with:

-   - Most liberal access to US markets for any country or region without at free trade agreement

-   - Reinforced Africa reform and development efforts, and

-   - Access to US credit and technical expertise.”

Other posts related to AGOA and textiles can be found here.

The Foundation for Democracy in Africa is likewise hosting an event on August 5, 2014 entitled “AGOA CSO Session: 13th US-Africa Trade and Economic Cooperation AGOA Forum.  This event will have a focus on human rights and democratic reform, among other topics.  Tickets are free but registration is required.

Questions or comments? Post below or email me at

Keep up with me at or:

On Twitter @fashcompliance

Thursday, July 24, 2014

CPSC Proposes Amending GCC Rules

Importers:  Did you know that the Consumer Product Safety Commission (CPSC) has proposed to amend the existing rule on the General Certificate of Conformity (GCC)?

Amendments including the requirement for the electronic filing of GCCs for regulated imported consumer products with U.S. Customs and Border Protection (CBP) at the time of filing the CBP entry, or the time of filing the entry and entry summary, are just some of the proposed amendments. 
Not keen on this idea?  You are in luck! 
 The CPSC recently voted to hold a workshop and seek additional public comments on aspects of its proposed rule on Certificates of Compliance, which the Commission first published on May 13, 2013.

Interested parties are invited to participate in, or attend the workshop, and to submit written comments.

The workshop will be held from 9 a.m. to 4 p.m. on Thursday, September 18, 2014 in the CPSC Hearing Room, 4th Floor of the Bethesda Towers Building, 4330 East West Highway, Bethesda, MD 20814.

Registration is now open using the following link, where you can also read the  formal notice by CPSC:

Questions or comments? Post below or email me at

Keep up with me at or:

On Twitter @fashcompliance

Tuesday, July 1, 2014

Is Your Scarf Flammable? Women’s Scarves Recalled Due to Flammability Hazard


If so, be advised that there’s been at least 1 report of these scarves catching fire and they have now been recalled by the Consumer Product Safety Commission as they failed to meet the federal flammability standard for wearing apparel and pose a risk of burn injury to consumers.
Both the Julie Vos “Sierra” and “Anchor” style scarves have been recalled.
The scarves, which are under the brand, Julie Vos, are 100 percent modal fabric, which is a type of rayon, and were sold in two prints, Anchor and Sierra. Anchor (on the left) was sold in three colors, including blue, green and orange. 

Sierra (on the right) was sold in four colors, including raspberry/magenta, orange/peach, cream/gray and blue/purple. The scarves measure 75 inches long by 45 inches wide and "Julie Vos" is printed on a tag sewn into the back of the scarf.

Manufactured in India, these imported scarves have been sold at specialty boutiques across the country and online at from January 2014 through February 2014 for about $165.  

Consumers should immediately stop using the recalled scarves and contact Julie Vos to arrange to return the scarves for a full refund. Julie Vos will provide a pre-paid postage label for shipping.

More information on the product recall may be found here:

Questions or comments? Post below or email me at

Keep up with me at or:

On Twitter @fashcompliance

Friday, June 20, 2014

US Postal Service is Grabbing Market Share Away From Express Couriers

This week I joined the Postal Customer Council for a presentation on the “International Misconceptions of the USPS,” which was presented by my friend, Kenyatta Adams.

While I was aware of changes USPS had been making in terms of increasing international shipments, I was unaware that it has 48% of the U.S. export market and grew 17% between 2011 and 2013.
What’s behind this?  E-Commerce of course, and the increase in wearing apparel sales which typically make for the ideal small and lightweight package.
At the pace the US Postal Service is moving, for small packages going outbound (exports) and inbound (imports) – I’ll explain that in a moment – there will be a lot of “moving and shaking” to keep an eye out for.

Imports have become streamlined thanks to their “Global Direct Entry (GDE) – Inbound” service.  Working with private international logistics providers, they can transport parcels from various foreign countries providing all logistics and brokerage activities.  The package is then handed off to USPS.

The caveat of course, is that shipments involving a certification or other form, such as a Fish and Wildlife declaration form (think, fur products, or a watch with a mother-of-pearl dial) cannot be sent through this type of service, and not all countries are yet a part of this GDE service.  But hey, it’s new and over time, more and more countries will be a part of it.  Currently, there are about 30 participating countries.

The top 3 highlights I learned about are:

1) USPS has International Tracking (yes, they do!), having rolled out “E-DELCON” last year

2) All returns are free for undeliverable packages in international shipping

3) Their service “METROPOST” is a same-day-delivery service in Manhattan and Brooklyn, USPS just has to receive it by 1 pm - this is great news for those of us in NYC!

With their competitive pricing in the 1 ounce to 70 pound packaging niche, not to mention their convenient flat rate envelopes and boxes, which I use, it is definitely not the USPS that it once was.

Questions or comments?

Post below or email me at
Keep up with me at or:
On Twitter @fashcompliance

Monday, June 16, 2014

I’m a Small Business. Does This Law Apply to Me Too?

My startups and smaller clients love to ask me this question. 

The answer to “Does size matter?” is for the most part pretty consistent, which is, “It depends!”

 It depends because even though there may be definitions of what a small business is, when the government puts out a new regulation, or an amendment to one, it may reason that because such new changes will have a limited impact on small businesses, that providing an exception for small businesses to compliance with the new rules is unnecessary.

Let’s take the recent amendments to the regulations for the Textile Fiber Products Identification Act (“the Rules”) as an example.

Under the Small Business Size Standards issued by the Small Business Administration, textile apparel manufacturers qualify as small businesses if they have 500 or fewer employees. 
Clothing wholesalers qualify as small businesses if they have 100 or fewer employees.
 The Federal Trade Commission’s (FTC) staff estimated that approximately 22,218 textile fiber product manufacturers and importers are covered by the disclosure requirements of these amended Rules.

While the FTC figured that a substantial number of these entities likely qualify as small businesses, it concluded that the amendments would not have a significant impact on small businesses because they do not impose any significant new obligations on them.

The FTC therefore, did not propose any specific small entity exception or other significant alternatives as it did not find it necessary to minimize the compliance burden, if any, on small entities while achieving the intended purposes of the amendments.

What do you think? Should smaller businesses be subject to less rigorous compliance requirements?

Post below or email me at

Keep up with me at or:

On Twitter @fashcompliance