FLA and AAFA submit comment to U.S. Trade Representative on proposed action in Section 301 investigations
In a public comment on proposed action in Section 301 investigations of U.S. trading partners related to prohibitions on the import of goods produced with forced labor, the Fair Labor Association (FLA) and the American Apparel & Footwear Association (AAFA) urged the U.S. Government to support industry and create effective frameworks to protect workers from forced labor abroad and at home.Â
The comment reads in part: “As the United States ratchets up its work to eradicate forced labor – most recently through the Section 301 investigations – it is vital that the U.S. Government redouble its efforts to eradicate forced labor that is all too present within our own borders…
“The current proposal to impose Section 301 tariff sanctions on over 50 of our trading partners because they do not also have a forced labor ban is both a threat and an aid to our sector…The threat comes from the fact that the imposition of tariffs would cause direct harm to our industry and potentially further jeopardize workers in the apparel and footwear supply chains. Implementation of Section 301 tariffs on imports from the investigated economies would raise landed costs, disrupt supply chains, and inflict direct harm on U.S. businesses, workers, and consumers…
“The aid comes from the proliferation of forced labor import bans. The more that our supply chain partners do to create effective forced labor enforcement mechanisms, the more successful we will be in eradicating forced labor. An uneven legal playing field means that some companies can take advantage of this discrepancy, leaving workers at risk and diminishing the efforts made in other markets. The question remains, however, whether Section 301 sanctions are the appropriate tool to achieve this level playing field. We urge you to consider limiting the scope and duration of the tariffs in favor of other means of diplomatic pressure and capacity building…
“Further, there are two problems that undermine the effectiveness of Section 301 sanctions. And the solution to both lies firmly within the purview of the U.S. Government. The first problem is forced labor in the U.S. prison system…The second problem involves the elimination of funding for support for effective implementation of laws and programs that directly lead to the eradication of forced labor in other countries.”
The associations together represent hundreds of American brands and retailers, employing millions of American workers, who are spending tremendous resources to ensure that the workers in their supply chains are working in a healthy and safe environment and paid well for their work.
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