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Nº 1 APRIL 2013, YEAR 14
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Centers for Excellence and Expertise; CBP’s Plan to Change Its Relationships with Importers
CBP will evaluate the test in three years, after which time CEE participation in some form could apparently become mandatory for all apparel, footwear and textile importers.
The CEE program was initiated in 2011 with the establishment of an electronics CEE in Long Beach, California and a pharmaceuticals, health and chemicals CEE in New York, New York. It was championed by former CBP Commissioner Alan Bursin, President Obama’s nominee and recess appointee who had to resign at the end of 2011 because the Senate did not act on his nomination, and the program has been promoted by the two Acting Commissioners who succeeded Bursin.
U.S. Customs and Border Protection (CBP) has embarked on an ambitious program to centralize important trade functions for the full spectrum of imported products in ten newly-created Centers for Excellence and Expertise (CEEs).
The CEE for apparel, footwear and textiles will be in San Francisco, California.
Following a three-year test period, CBP’s ultimate goal is to transfer these trade-related functions away from the ports of entry, where they have resided in various forms for more than 200 years, until they are conducted entirely by the CEEs.
CBP will start accepting applications from apparel, textile and footwear companies desiring to participate voluntarily in the San Francisco CEE test program on June 3, 2013 and will select the �rst participants by July 3, 2013.
Jon Fee and BJ ShannonAlston & Bird LLPApril 8, 2013
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Two more CEEs, an automotive and aerospace CEE in Detroit, Michigan and a petroleum, natural gas and minerals CEE in Houston, Texas, were established in 2012. On April 4, 2013, CBP published a notice broadening the general authority of the CEEs and con�rming the establishment of the apparel, footwear and textiles CEE in San Francisco along with other CEEs for other products in other parts of the United States.
According to the notice of April 4, 2013, more than 80 di�erent sections of the U.S. Customs Regulations, plus all of the sections of those regulations concerning administration of free trade agreements and trade preference programs, are “waived” for the duration of the test so that CEE directors will have the authority to make decisions formerly reserved for port directors at the several U.S. ports of entry. The April 4, 2013 notice refers to CEE guidelines published in August 2012 and requires participants to check those guidelines on a weekly basis for updates and changes. Together, the notice and the guidelines make clear that most post-entry activity will be handled by the
CEEs. Participants will continue to �le entries and entry summaries at ports of entry where they import their merchandise and will pay duties at those ports; but entry data will be transmitted to the CEE for virtually all further processing.
Thus, for example, if a participant’s entry is rejected, the rejection notice will be issued by the CEE. The CEEs, and not the ports, will issue requests for information and notices of action to participants. CBP often issues requests for information to request samples or documentation to con�rm tari� classi�cation, value, or other entry claims and issues notices of action to make corrections and to collect additional duties where CBP disagrees with the importer’s entry.
In the apparel industry, requests for information and rate advances often relate to documentation supporting eligibility for free trade agreements (such as NAFTA and CAFTA) or preference programs (such as duty free treatment for eligible imports from Haiti or sub-Saharan African countries) and to deny free trade agreement or preference program treatment if CBP �nds the documentation to be insu�cient.
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Most other post entry summary processes will also be handled by the CEEs. These include liquidations of entries, protests and requests for internal advice. Liquidation is the �nal computation of duties on imported merchandise.
Protests are �led by importers, usually seeking refunds of duties, who disagree with liquidations and certain other CBP decisions. Internal advice requests are �led by importers seeking rulings on pending transactions.
According to the CEE guidelines, reconciliation processing will still take place at assigned ports of entry. Reconciliation is a program under which participating importers periodically �le information (such as value information) pertaining to groups of their entries that is not known at the times of entry of the a�ected merchandise. CBP evidently intends to transfer the reconciliation program to the CEEs at some time in the future. Enforcement actions, involving penalties, seizures and liquidated damages claims against the importer’s bond, will continue to be administered by local ports. Originally, prior disclosures (under which participants
disclose violations to curtail penalties) were supposed to be �led by participants with the CEEs; but the April 4, 2013 notice says that participants may choose to �le prior disclosures either at the ports of entry or at the CEEs. The April 4, 2013 notice warns that CBP can penalize participants for “misconduct” under the program. Misconduct could include, for example, failure to abide by the program’s terms or conditions or to exercise reasonable care in the execution of participant obligations.
The greatest advantage of CEE participation is uniformity of treatment. Importers have long complained that di�erent CBP ports often treat the same transactions di�erently or that CBP ports often raise issues or ask questions that have already been resolved or answered at other ports. CBP claims that CEE’s will make CBP more e�cient and will give CBP better understanding of the relevant industries and their products.
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But many importers already have close, productive relationships with local ports and may be reluctant to transfer their customs business to a CEE, like San Francisco, hundreds or even thousands of miles away.
It is also unclear how CBP will shift human resources to San Francisco from principal textile and apparel ports (such as New York, Long Beach and Miami) where CBP personnel presently have considerable experience and expertise.
This is particularly troubling for importers who rely heavily on CAFTA and NAFTA, for example, because San Francisco CBP personnel have limited experience and expertise relating to these programs.
CBP has indicated, however, that persons with expertise from other ports might be “virtually” linked to the CEE to participate in CEE activities.
It remains to be seen whether CBP’s initial enthusiasm lasts for the length of the three-year test program, whether a su�cient number of signi�cant importers will volunteer to make the test results meaningful and whether the program becomes mandatory in substantially its present form.
Interested importers are encouraged carefully to consider participation and to monitor the evolution of the test so they will be prepared for the change to CEEs, if necessary, after the test is complete.
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Alamac American Knits, LLC
1885 Alamac RoadP.O. Box 1347Lumberton, NC 28359Phone: (910) 618-2200Fax: (910) 618-2292www.alamacknits.com
Contact name/number:
Mark Cabral, PresidentO�ce: (910) 618-2235Cell: (910) 734-5027Email: [email protected]
Don PugatchVP SalesO�ce: (770) 649-8077Cell: (678) 770-7977Email: [email protected]
Ron GiaconeVP SalesO�ce: (516) 255-9491Cell: (516) 902-4639Email: [email protected]
List of Senior Management:
Mark Cabral, PresidentHenry Gri�n, VP ManufacturingDoris Sampson, VP PlanningRobert Hester, Chief Financial O�cer History of Company:
The history of Alamac American Knits dates back to the mid 1940s when its co-founders, Alan Kaplan and Mac Thal started a small circular knitting operation in Indian Orchard, Massachusetts. The company was relocated to Lumberton, NC in 1962 and was subsequently purchased by WestPoint Pepperell in 1969. Today, Alamac is privately owned and is managed by an experienced group of managers, some of which are second-generation employees of Alamac. The entire management team at Alamac has a vast knowledge of all aspects of apparel manufacturing.
Alamac has a 415,000 square foot facility situated on 192 acres in Lumberton, NC. We are logistically located on the I-95 / Highway 74 corridors, which is situated between two major seaports located at Wilmington, NC and Charleston. Our production capacity is in the range of 500,000 yards of �nished fabric per week. We are a vertical, made to order circular knit, dye, and �nish manufacturer. We also o�er commission dyeing and �nishing services for both knits and woven fabrics. Alamac services a wide variety of end use markets including the industrial rental uniform, career workwear, protective wear, US military, and private label markets.
We are known for our extensive product capabilities in piece dye and yarn dye knit construc-tions, product integrity, and exceptional customer service. Research and development is a primary focus to continually innovate and expand our product o�erings. We produce fabric made from a wide range of traditional �bers including 100% polyester performance �bers, 100% cotton, and poly/cotton blends. We also manufacture many specialty items such as 100% wool, wool blends, natural �ber blends, and a wide variety of Flame Resistant �bers for the protective wear markets.
At Alamac, customer service means total satisfaction for our customers, our employees, and our suppliers.
Machine Availability Includes:
Single knit 4 track raceway machines: 16 – 28 gaugesAutomatic striper machines: 16 – 28 gaugeDouble knits machines: 18 – 28 gauge8-lock interlock machines: 18 and 24 gaugeFleece machines: 2-end and 3-endTerry machines: 16 – 20 gaugeRib machines: 14 and 18 gaugeFleece machines: 2-end and 3-endFashion collars and welts
Jemco bleach rangeGaston County pressure jet dye machinesSclavos Over�ow dye machinesThen Air Flow pressure jet dye machines
Open width pin tenter �nishing framesRelax belt dryersTubular suction drum dryersTubular and open width compactorsNapping / sheering
Products:
Alamac’s single knit product capabilities include: Singe knit jersey, novelty and texture stitches, meshes, feed stripes, automatic engineered stripes and jacquards, french terry, �eece and terry. Our double knit capabilities include: interlock, jacquards, ponti-de-roma, cable knits, regular and �at back ribs, meshes, thermals, collars and welts. End Uses:
Industrial rental uniforms, career apparel, protective apparel, performance apparel, base layer, golf, sportswear, childrenswear, school uniform, collegiate and sport apparel, military, and private label.
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American Denimatrix
Plant:1926 FM 54Little�eld, TX 79339Telephone: +1 806 385-6401Fax: +1 806 385-5155www.pcca.com
Denim sales/marketing:980 Avenue of the Americas2nd FloorNew York, NY 10018Telephone: +1 212 494-0101Fax: +1 212 494-0150
Contact name/number:
Mr. Jack MathewsVice President of Sales and MarketingTelephone: +1 212 494-0101Fax: +1 212 494-0150 List of Senior Management:
Mr. Wally L. Darneille, PCCA President & CEOMr. Bryan Gregory, Vice President of Textile ManufacturingMr. Jack Mathews, Vice President of Sales and Marketing
History of Company:
American Denimatrix represents the textile and apparel division of Plains Cotton Cooperative Association, a farmer owned Cotton Cooperative founded in 1953, in Lubbock Texas.
We operate the only fully vertically integrated supply chain for denim fabric and apparel in the western hemisphere. The process begins with cotton grown by our farmer members, which we manufacture into denim fabric at our facility in Little�eld Texas (formerly known as
American Cotton Growers or "ACG"). In 2009 we created Denimatrix, a full package garment facility located in Guatemala City. Deminatrix is dedicated to developing innovative, fashion driven jeans for leading brands and retailers.
Our unique business model allows us to tailor solutions that address each customers needs. Whether it's selling fabric or developing an entire �oor ready garment collection, we have the knowledge, resources and technology that enable us to exceed customer’s expectations.
Products:
Fabric – Our o�ering includes a complete line of bottom weight indigo dyed denim fabric in 100% cotton and cotton and spandex blends. We produce a variety of yarn types including open end, amsler open end, ring spun, amsler ring spun and core spun for stretch denim. This enables us to serve a broad range of customers and market segments.
Garments- Denimatrix produces fashion jeans, skirts and related apparel for the male and female Jeanswear markets. We specialize in developing innovative market right �nishes at a competitive price. Our �nancial strength has enabled us to make signi�cant investments in "Eco �nish” capability such as lasers and ozone washing machines. In addition we also have garment dye capability.
End Products Supplied:
Denim fabrics for jeans, shorts, skirts, and jackets
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Buhler Quality Yarns Corp.
1881 Athens Hwy.Je�erson, GA 30594Telephone: +1 706 367-9834Fax: +1 706 367-9837E-Mail: [email protected]
Contact Name / Number:
Mr. David Sasso, VP of International SalesTelephone: +1 706 367-3931Fax: +1 706 367-9837E-Mail: [email protected]
Mr. Victor Almeida, Technical SupportTelephone: +1 706 367-3934Fax: +1 706 367-9837E-Mail: [email protected] List of senior management:
Mr. Russell Mims, Operations ManagerMs. Kelly Ouellette, Sales & Customer ServiceMr. David Sasso, Vice-president International SalesMr. Victor Almeida, Textile Engineer & Technical SupportHistory of company
The Industry Leader: Buhler Quality Yarns Corp. ensures the highest quality products backed by environmental sensitivity and around-the-clock support throughout your supply chain. Our distinctive portfolio o�ers Supima®, MicroTencel®, Micro Modal® and various blends fabricated to exceed expectations.
Additional yarns include fashion slub yarns in Supima and Supima Micro Modal; all o�er comfort, durability, and strength. Bring your product to market backed by decades of experience, dependable industry relationships and unsurpassed technical support. Our yarns are spun in the USA and comply with all USA trade agreements. For more information, visit www.buhleryarns.com
Products:
100% Supima cotton combed Ring Spun
Micro Modal MicroModal from Ring Spun, MicroModal Supima Ring Spun, MicroTencel Ring Spun
Applications:
Weaving (warp and Filling)Knitting (Circular, Seamless, Warp)Cotton sewing thread
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Carolina Cotton Works, Inc. - CCW
14 Commerce DriveMeadow Creek Industrial ParkGa�ney, SC 29340Phone: (864) 488-2824Fax: (864) 488-0488www.carolinacotton.com
Contact name/number:
Mr. Bryan Ashby, Vice President, Sales & MarketingPhone: (864) 488-2824Fax: (864) 488-0488E-mail: [email protected]
Mr. Stacey Bridges, Sales ManagerPhone: (864) 488-2824 ext.108Fax: (864) 488-0488E-mail: [email protected] List of senior management:
Mr. Page Ashby, PresidentMr. Bryan Ashby, Vice President, Sales & MarketingMr. Hunter Ashby, Operations ManagerMr. Stacey Bridges, Sales Manager
History of company:
Carolina Cotton Works, Inc. (CCW) opened for business in March of 1995. Starting out in a new building and all new equipment, we soon earned a reputation of having one of the �nest dyehouses in the United States. With continued success each year since, CCW has reinvested in new equipment and systems to allow us to stand alone as the most e�cient dyehouse in the country. Although we continue to o�er commission bleaching and dyeing services, the growth of our business has proven to be in the �nished fabric package business. Most recently, CCW is pleased to be recognized as a bluesign® system partner.
Experience - Quality - Dependability - Three necessary components of strong customer/vendor relationships have been the key building blocks of Carolina Cotton Works. With the experience of company president Page Ashby, comes knowledge of yarn spinning through cutting. We have built solid relationships with several major yarn spinners and knitters in the United States. We have the resources and technical abilities to become the premier U.S. fabric supplier for apparel producers both domestic and international.
Using the state of the art equipment in our 120,000 square foot building, Carolina Cotton Works can produce up to 450,000 pounds per week of bleaching and piece dyeing.
Equipment listing:
JEMCO III 2000 CBR; (7) 1000 lb. Scholl Rapidstar Jets; (1) 80 lb. Scholl Sample Jet; (5) Fong Horizontal Dye Jets; (2) Santex Relaxed Belt Dryers; (3) Tubetex Pak-Nit II Compactors; RFG Napper; Mario Crosta Brushing Machine; Texima Natural Gas Tenter Frame; Strahm Open Width Compactor; (2) Tubetex 4-Roll Pads; Santex Shrinking Calendar.
Products
All types of cotton and poly cotton knits and wovens, both body sizes and open width. Many synthetics including circular knits and wrap knits, Interlock, French Terry, Thermal Performance Fabrics, and ANSI Fabrics. Other �ber types dyed include nylon and modacrylic.
End Products Supplied
Customers use CCW's fabric to manufacture outerwear products such as t-shirts, rib tops, golf shirts, sweatshirts and sweatpants. Underwear products include briefs, t-shirts and thermal underwear. We also process synthetic fabrics used for moisture transport performance apparel and team sports uniform apparel.
2013 U.S. Crop OutlookPrepared by:
Economic Services - National Cotton Council
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The U.S. Department of Agriculture (USDA) released their �rst U.S. crop outlook for the upcoming season. USDA placed the estimated 2013/14 U.S. cotton plantings at 10.03 million acres, down 18.6% from 2012. Upland planted area is estimated to have decreased 18.7% to 9.82 million acres. Extra long staple producers planted 206,000 acres, down 13.6% from 2012. USDA will release an updated projection of propsectieve plantings in June.
The National Cotton Council’s planting intentions survey, released in early February, indicated US farmers intend to plant 8.81 million acres of upland cotton and 203,000 acres of ELS.
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Prospective 2013 U.S. Cotton PlantingsIn 1000 acres
2012 USDA Actual
2013 USDA Estimate
2013 NCC Planting
Intentions
USDA Percent Change
NCC Percent Change
UPLAND SOUTHEAST 2,748 2,580 2,241 -6.1% -18.5%Alabama 380 360 320 -5.3% -15.7%Florida 108 115 103 6.5% -4.5%Georgia 1,290 1,300 1,093 0.8% -15.3%North Carolina 585 450 398 -23.1% -32.0%South Carolina 299 290 265 -3.0% -11.4%Virginia 86 65 62 -24.4% -28.3%MID-SOUTH 2,030 1,260 1,003 -37.9% -50.6%Arkansas 595 270 221 -54.6% -62.9%Louisiana 230 170 144 -26.1% -37.3%Mississippi 475 270 199 -43.2% -58.1%
Missouri 350 270 239 -22.9% -31.6%Tennessee 380 280 199 -26.3% -47.6%SOUTHWEST 6,911 5,700 5,228 -17.5% -24.4%Kansas 56 40 50 -28.6% -10.4%Oklahoma 305 160 267 -47.5% -12.3%Texas 6,550 5,500 4,910 -16.0% -25.0%WEST 388 280 341 -27.8% -12.2%Arizona 200 160 193 -20.0% -3.6%California 142 90 112 -36.6% -21.4%New Mexico 46 30 36 -34.8% -21.0%TOTAL UPLAND 12,077 9,820 8,812 -18.7% -27.0%TOTAL ELS 238 206 203 -13.6% -15.0%Arizona 3 1 3 -66.7% -16.0%California 225 190 190 -15.6% -15.6%New Mexico 2 4 2 66.7% -26.0%Texas 8 11 8 37.5% 3.9%ALL COTTON 12,315 10,026 9,015 -18.6% -26.8%
COTTON COUNCILINTERNATIONAL HEADQUARTERS & LATIN AMERICA
1521 New Hampshire Avenue, NWWashington, DC 20036, USAPhone: (202) 745-7805Fax: (202) 483-4040
Vaughn Jordan,International Program DirectorEmail: [email protected]
CBI OFFICE:C.C. Plaza Colonial Oficina 1-11A,San Rafael de Escazú, San José, Costa RicaPhone: (506) 2288-2626 / 2289-8680Fax: (506) 2289-5124
Floribeth González-SchuylerRegional Manager,México,Central America & The CaribbeanEmail: [email protected]
ANDEAN OFFICE:Cra. 14 No. 94A-44Office 402Bogota, ColombiaPhone: (57) 1-623-3132Fax: (57) 1-623-3076
Nina Maldonado, Regional Manager, Andean RegionEmail: [email protected]
KOREAN OFFICE:Leema Building, Suite 303, 146-1Soosong-Dong, Chongro-KuSeoul 110-755, KoreaPhone: (011-82-2) 722-3681/2Fax: (011-82-2) 722-3684
Won-Jung Choi,Program ManagerEmail: [email protected]
COTTON INCORPORATEDHEAD OFFICE
6399 Weston Parkway Cary,NC 27513, USAPhone: (919) 678-2326Fax: (919) 678-2231
LATIN AMERICA OFFICE:Av. Insurgentes Sur 1605 - 9 - C03900 Mexico, DF, MexicoPhone: (52-55) 5663-4020Fax: (52-55) 5663-4023
Jaime FloresDirector, Supply Chain Marketing – Latin AmericaGlobal Account Management GroupEmail: [email protected]
