Carlos Moore, executive vice president of the American Textile Manufacturers Institute (ATMI), wrote in his Nov. 9 letter, "The African Growth Act needed some work," that the bill was "badly flawed." But he made some seriously flawed statements of his own concerning the bill. His terminology and inaccuracies must be rectified.
Mr. Moore suggested that passing the bill would lead to a flood of clothing being illegally transshipped from China through Africa to the United States. To support this assertion, Mr. Moore said the U.S. Customs Service has "already caught China illegally shipping textile and apparel through eight sub-Saharan African nations." The U.S. Customs Service has chastised Mr. Moore for his past exaggerations on the risk of transshipment through Africa. In a May letter, Janet Labuda, director of international trade management at the Customs Service, advised Mr. Moore, "I am very concerned by the fact that false and misleading information was disseminated [to the House Ways and Means Committee in ATMI's statement on the Africa bill] and that this information was attributed to U.S. Customs."
Miss Labuda then contradicted Mr. Moore's past assertions about transshipment through Africa: "While it is true that we have found some transshipment from sub-Saharan countries, we would not consider these significant or part of any organized pattern. The most recent transshipment findings were isolated instances generally occurring prior to 1996." Miss Labuda went on to say that sub-Saharan Africa is not a "major transshipment point."
In the Customs Service's most recent list of known and suspected textile and apparel transhippers, published this September, not a single African company was identified.
Furthermore, the U.S. standard rule of country of origin for textiles and apparel (commonly called the Breaux-Cardin rule) states that "the country . . . in which the most important assembly or manufacturing process occurs" will be the country of origin. The African Growth Act is based on the Breaux-Cardin rule. …