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U.S.-Korea Free Trade Agreement: Potential Economy-wide ... - USITC

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passage. NCTO indicated that, even if these zones were never granted FTA status, the<br />

likelihood exists of significant transshipments from the zones to the United States.<br />

The American Manufacturing <strong>Trade</strong> Action Coalition (AMTAC), a trade association<br />

representing a <strong>wide</strong> range of industrial sectors, including textiles and apparel, stated in a<br />

written submission to the Commission that, given <strong>Korea</strong>’s current capabilities as a major<br />

producer and exporter of industrial goods, the FTA will be a “major blow” to the U.S.<br />

manufacturing base, especially for textiles and apparel. 331 It expressed concern over <strong>Korea</strong>’s<br />

history of using unfair trading practices and questioned whether U.S. Customs would be able<br />

to monitor and enforce the FTA. According to AMTAC, given <strong>Korea</strong>’s proximity to China,<br />

where production costs are much lower, China will have an enormous incentive to take<br />

advantage of <strong>Korea</strong>’s zero-duty access to the U.S. market through illegal transshipments and<br />

false documentation. AMTAC noted that the FTA would present unique concerns beyond<br />

those associated with previous FTAs such as CAFTA-DR, where the free trade partners<br />

generally were apparel assemblers with limited textile capabilities. AMTAC stated that the<br />

FTA would grant <strong>Korea</strong> immediate duty-free access to the U.S. market for 60 percent of the<br />

textile product categories that it identifies as sensitive, including those covered by the U.S.-<br />

China Textile Bilateral <strong>Agreement</strong>, threatening both U.S. domestic sales and U.S.<br />

coproduction relationships in the NAFTA/CAFTA region. AMTAC indicated that the FTA<br />

tariff phaseout schedule would likely undermine the U.S.-China Textile Bilateral <strong>Agreement</strong><br />

and create increased potential for illegal transshipments in the region. AMTAC also stated<br />

that <strong>Korea</strong> has limited ability to consume finished goods manufactured in the United States<br />

and that it expects to see a significant increase in the U.S. trade deficit and the loss of more<br />

textile and apparel jobs in the United States as a result of the FTA.<br />

The American Apparel & Footwear Association (AAFA), a national association representing<br />

apparel and footwear companies and their suppliers, stated in a written submission to the<br />

Commission that it supports passage of the FTA but expressed concern that the “restrictive<br />

and cumbersome” rules of origin and “less-than-ambitious” tariff phaseout schedule for<br />

textiles and apparel would provide little incentive to further develop trade with <strong>Korea</strong> in<br />

textiles and apparel. 332 It noted that “well over one-half” of current U.S.-<strong>Korea</strong> apparel and<br />

textile trade would receive less than immediate and reciprocal duty-free treatment. AAFA<br />

expressed concern about the FTA short-supply provision, noting that there are currently no<br />

fibers, yarns, or fabrics designated as not commercially available in the FTA region or to<br />

include items already designated in short supply under other U.S. trade programs. AAFA<br />

also noted that the FTA would place quantitative limits on the volume of fabrics and apparel<br />

made of short-supply inputs that would be eligible for FTA preferences. AAFA also<br />

indicated that the absence of “cumulation” provisions that permit integration of inputs among<br />

U.S. FTA partners would limit opportunities to create new markets for U.S. textile and<br />

apparel exports that flow through FTA partners (such as garments made with U.S. fabric in<br />

Guatemala exported to <strong>Korea</strong>). AAFA viewed the apparel and textile provisions in CAFTA-<br />

DR as a model that would have worked well in the U.S.-<strong>Korea</strong> FTA because, according to<br />

AAFA, CAFTA-DR provisions are designed to create export opportunities for U.S. textile<br />

firms and provide the region with the tools it needs to effectively compete: cumulation, a<br />

“robust” short-supply list, a single transformation rule of origin for key goods, a yarn-<br />

331 Tantillo, “U.S.-<strong>Korea</strong> <strong>Free</strong> <strong>Trade</strong> <strong>Agreement</strong>: <strong>Potential</strong> <strong>Economy</strong>-<strong>wide</strong> and Selected Sectoral Effects,”<br />

written submission to the <strong>USITC</strong>, June 27, 2007.<br />

332 Lamar, “Re: U.S. International <strong>Trade</strong> Commission Inv. No. TA-2104-24 (May 7, 2007)–U.S.-<strong>Korea</strong><br />

<strong>Free</strong> <strong>Trade</strong> <strong>Agreement</strong>,” written submission to the <strong>USITC</strong>, June 27, 2007.<br />

3-58

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