Changes to the Rules Under the Wool Products Labeling Act of 1939?

You now have a few more days to send in your comments! New Deadline – 12/3/13   

 The Federal Trade Commission (FTC) published a Notice of Proposed Rulemaking on September 20, 2013 seeking comments on its proposed amendments to the rules and regulations under the Wool Products Labeling Act of 1939.  Comments were originally due on November 25, 2013.

Interestingly, an extended deadline of December 3, 2013 to submit comments has occurred due to a request from the Embassy of Australia to the FTC.

On November 20, 2013, the Embassy of Australia contacted the Commission on behalf of the Federation of Australian Wool Organisations (“FAWO”) to seek an eight (8) day extension since it was participating in a meeting of the International Wool Textile Organisation (“IWTO”) in Guangzhou, China, on November 25-26, 2013, to discuss the FTC's proposed amendments.

FAWO contended that the FTC’s record would benefit from comments collected at the meeting given the role of the IWTO in representing wool industry stakeholders at an international level.

The FTC likewise believes that the FAWO’s input would likely assist the Commission in evaluating the proposed amendments to the Wool Rules.

Since the requested short extension of the comment period would not substantially delay the rulemaking process and the FTC believed that extending the comment period to facilitate a more complete record outweighed any harm that might result from an eight (8) day delay, it agreed to the extend the comment period until December 3, 2013.

For more information, you can contact Robert M. Frisby, Attorney, (202) 326-2098, Division of Enforcement, Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue, NW, Washington, DC 20580.

Questions/comments?  Post below or email me at clark.deanna@gmail.com  

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Does Your New Pair of Shoes Have a Fuzzy Bottom? CBP’s New ISO 20871 Determination

Strange but true, in certain cases where a textile material covers the “outermost sole” of a rubber or plastic soled shoe, the duty rate on such imported shoe may be lower than if the sole were without the “fuzz.”

This results because such textile coating can move an importation of footwear from one category, i.e., classification, to another, and with such move can come an accompanying change in the rate of duty (and possibly one that is favorable to the importer – think cheaper).

For anyone not well-versed in tariff-ease, all this really means is that a fuzzy bottom can cost less to import in to the US than one that is bare.

In case it is not obvious, the “outer sole” is that part of footwear (other than an attached heel) which, when in use, is in contact with the ground, i.e., the bottom of the shoe.

Since a more favorable duty rate may, at times, be obtained where footwear has an outer sole of textile, it’s not uncommon to find importers buying footwear that has a thin textile coating on the bottom (which can feel fuzzy) and then classifying the footwear under the tariff number for shoes having textile on its sole in order to take advantage of these duty savings.

Since US Customs is in the business of collecting as much money in duties (revenue) as possible, in an effort to curb inappropriate usage of such classifications, it routinely requests more information on imported shipments to confirm that the textile is actually there.

Starting this month (Nov. 2013), US Customs has decided that the ISO 20871 test method will be recognized in assessing the characteristics of the textile material attached to outer soles.

This means that when an importer is asked to provide more information (Customs Form 28) about a textile covered sole, an analysis performed by an independent lab using this test method (ISO 20871) should be presented.

 Also, keep in mind that US Customs can always conduct its own testing when circumstances warrant it.

To learn more about the impact of this, the newly branded US Fashion Industry Association (formerly USITA) is having a webinar on this.  More information on the event can be found here.

Questions/comments?  Post below or email me at clark.deanna@gmail.com  

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