Determination by the Department of Commerce on the Wholly Formed Requirement for Qualifying Woven Fabric Under the Dominican Republic Earned Import Allowance Program, 45603-45605 [2010-19065]
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Federal Register / Vol. 75, No. 148 / Tuesday, August 3, 2010 / Notices
related matters to the attention of the
Committee may file written statements
with the Committee staff before or after
the meeting.
Dated: July 28, 2010.
Tina J. Terrell,
Forest Supervisor.
[FR Doc. 2010–19023 Filed 8–2–10; 8:45 am]
BILLING CODE 3410–11–P
DEPARTMENT OF COMMERCE
International Trade Administration
Determination by the Department of
Commerce on the Wholly Formed
Requirement for Qualifying Woven
Fabric Under the Dominican Republic
Earned Import Allowance Program
July 29, 2010.
Department of Commerce,
International Trade Administration.
ACTION: Notice.
AGENCY:
The Department of Commerce
has determined to maintain the current
interpretation of the wholly formed
requirement of qualifying woven fabric
under the Dominican Republic Earned
Import Allowance Program (DREIAP).
FOR FURTHER INFORMATION CONTACT:
Robert Carrigg, Office of Textiles and
Apparel, Import Administration, U.S.
Department of Commerce, (202) 482–
2573.
SUPPLEMENTARY INFORMATION:
Authority: Section 2(a) of the Andean
Trade Preference Extension Act of 2008
(‘‘ATPEA’’); Section 404(b)(2)(H) of the
Dominican Republic-Central AmericaUnited States Free Trade Agreement
(‘‘CAFTA–DR FTA’’) Implementation
Act, as amended; Imports of Certain
Apparel Articles: Interim Procedures for
the Implementation of the Earned
Import Allowance Program Established
Under the Andean Trade Preference
Extension Act of 2008 (74 FR 3563,
published January 21, 2009) (‘‘Interim
Procedures’’).
DATES: Effective Date: August 3, 2010.
erowe on DSK5CLS3C1PROD with NOTICES
SUMMARY:
Background
On December 1, 2008, the Department
of Commerce implemented provisions
under the Andean Trade Preference
Extension Act of 2008 (Pub. L. 110–436,
122 Stat. 4976) (ATPEA or
implementing legislation). Section 2 of
the ATPEA amends Title IV of the
CAFTA–DR FTA Implementation Act
(Pub. L. 109–53; 119 Stat. 495).
Specifically, Title IV of the CAFTA–DR
FTA Implementation Act is amended by
adding Section 404, creating a benefit
for eligible apparel articles wholly
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14:41 Aug 02, 2010
Jkt 220001
assembled in the Dominican Republic
that meet the requirements for a ‘‘2 for
1’’ earned import allowance. Section 2 of
the ATPEA requires the Secretary of
Commerce to establish a program to
provide earned import allowance
certificates to any producer or entity
controlling production of eligible
apparel articles in the Dominican
Republic, such that apparel wholly
assembled in the Dominican Republic
from fabric or yarns, regardless of their
source, and imported directly from the
Dominican Republic, may enter the
United States duty-free, pursuant to the
satisfaction of the terms governing
issuance of the earned import allowance
certificate. The Secretary of Commerce
has delegated his authority under the
CAFTA–DR FTA Implementation Act to
implement and administer the Earned
Import Allowance Program to the
International Trade Administration’s
Office of Textiles and Apparel
(‘‘OTEXA’’).
On January 21, 2009, OTEXA
published interim procedures, 74 FR
3563, implementing Section 2 of the
ATPEA. These procedures set forth the
provisions OTEXA will follow in
implementing the DREIAP. In
accordance with these procedures,
OTEXA issues certificates to qualifying
apparel producers to accompany
imports of eligible apparel articles
wholly formed in the Dominican
Republic and exported from the
Dominican Republic. Such certificates
will be issued as long as there is a
sufficient balance of square meter
equivalents available as a result of the
purchase of qualifying woven fabric.
‘‘Qualifying woven fabric’’ is defined in
Section 2 of the ATPEA and in OTEXA’s
interim procedures as ‘‘woven fabric of
cotton wholly formed in the United
States from yarns wholly formed in the
United States’’ and intended for
production of apparel in the Dominican
Republic. See Section 2(e) of the Interim
Procedures; Section 404(c)(4) of the
CAFTA–DR FTA Implementation Act,
as amended by Section 2 of the ATPEA.
Neither the ATPEA nor the interim
procedures define the term ‘‘wholly
formed’’ as it is used in the definition of
‘‘qualifying woven fabric.’’
OTEXA received inquiries regarding
the interpretation of ‘‘wholly formed’’ as
a requirement under the definition of
‘‘qualifying woven fabric.’’ Accordingly,
on April 3, 2009 (74 FR 15254), OTEXA
requested public comment on the
intended meaning of the ‘‘wholly
formed’’ requirement in the definition of
‘‘qualifying woven fabric’’ for the
purposes of the DREIAP. In that request
for public comment, OTEXA explained
that it ‘‘currently interprets ‘wholly
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45603
formed’ within the definition of
‘qualifying woven fabric’ to require that
all production processes and finishing
operations, starting with weaving and
ending with a fabric ready for cutting or
assembly without further processing,
take place in the United States.’’ Id., 74
FR at 15255.
OTEXA received ten comments and
has carefully analyzed the points raised
in each submission. These comments
are available on OTEXA’s Web site at
https://web.ita.doc.gov/tacgi/otexa_dr_
eiap_publiccomments.nsf/
504ca249c786e20f85256284006da7ab?
OpenView&Start=1. Department
officials have also discussed this matter
on several occasions with interested
stakeholders to ensure that all points
have been considered.
Commentators that support OTEXA’s
current interpretation contend that the
DREIAP was intended to improve the
competitiveness of Dominican apparel
producers and create new export
opportunities for United States
manufacturers of qualifying fabrics.
These commentators suggest that from
the beginning, it was clear that the
intent was to base the program on the
delivery of qualifying fabric ready for
cutting and sewing into trousers. There
was never any discussion of permitting
greige fabric (raw fabric that has yet to
be bleached or dyed) to be shipped to
another country for finishing and
allowing such fabric to qualify for
benefits under the program because it
was understood that support from
United States industry was dependent
on the requirement that fabric be
produced and finished in the United
States so that it would be ready for
cutting and sewing upon arrival in the
Dominican Republic. These
commentators argue that effective
enforcement of the program would be
more difficult if third countries were
able to participate as finishers. They
also contend that the dyeing and
finishing stage imparts distinct
characteristics that only then make the
fabric suitable for a specific apparel
application as envisaged by the
legislation. Unfinished fabric can be
used for applications other than the
assembly of trousers and similar
garments. The commentators contend
that although the program was enacted
as an amendment to the CAFTA–DR
FTA Implementation Act, it could have
been implemented as a stand-alone bill
or as an amendment to other relevant
legislation. These commentators suggest
that the connection between the
program and the vehicle to which it was
attached is one of legislative
convenience. These commentators state
that at no time was there an expression
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03AUN1
45604
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erowe on DSK5CLS3C1PROD with NOTICES
to treat the program as other than a
preferential program and at no time was
it contemplated that the finishing of
qualifying fabrics could take place
outside the United States.
Furthermore, these commentators
state that allowing finishing outside the
United States does not preserve or
promote the use of United States fabrics
as intended by the program. Lastly,
these commentators contend that there
is more than sufficient capacity in the
United States to dye, print, and finish
the amount of fabric required by
Dominican Republic apparel
manufacturers for qualification under
the program.
Commentators who disagree with
OTEXA’s current interpretation assert
that the term ‘‘wholly formed’’ as used
in the DREIAP does not require the
fabric to be dyed and finished in the
United States, and that such an
interpretation negates the benefits of the
program. These commentators contend
that this issue was never addressed
during the discussions leading to the
creation of the program. As such, they
contend that OTEXA’s current
interpretation was not contemplated in
the drafting of the legislation and is not
required under the express terms of the
legislation. They argue that Customs
and Border Protection (‘‘CBP’’)
interpreted the term ‘‘wholly formed’’
when used in the Caribbean Basin Trade
Preference Act (‘‘CBTPA’’) of 2000 (Pub.
L. 106–200, 114 Stat, 251, 2766) as not
requiring dyeing and finishing. These
commentators contend that Congress
did not amend the definition of ‘‘wholly
formed’’ in the Trade Act of 2002 (Pub.
L. 107–210), but only added a new
requirement. These commentators state
that because the DREIAP is not an
amendment to the CAFTA–DR FTA, the
requirements for dyeing and finishing
specified in two footnotes in that
agreement do not apply to the term in
this program. They contend that there is
no requirement to directly ship
qualifying fabric to the Dominican
Republic; therefore, dyeing and
finishing of United States greige fabric
is not precluded. They argue that
OTEXA’s interpretation is inconsistent
with other similar programs. Finally,
these commentators argue that
originating apparel under free trade
agreements need not be dyed or finished
by the parties.
Analysis and Determination
After careful consideration of the
interested party comments, OTEXA has
determined it will continue to interpret
‘‘wholly formed’’ within the definition of
‘‘qualifying woven fabric’’ to require that
all production processes and finishing
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14:41 Aug 02, 2010
Jkt 220001
operations, starting with weaving and
ending with a fabric ready for cutting or
assembly without further processing,
take place in the United States under
the DREIAP.
Neither the ATPEA nor the interim
procedures define the term ‘‘wholly
formed’’ as it is used in the definition of
‘‘qualifying woven fabric.’’ Additionally,
there is no legislative history regarding
this term as it is used in this program.
Although not controlling, OTEXA
considered testimony given by former
Special Textile Negotiator for the United
States Trade Representative, Scott
Quesenberry. See Testimony before the
United States International Trade
Commission on the matter of the Earned
Import Allowance Program: Evaluation
of the Effectiveness of the Program for
Certain Apparel from the Dominican
Republic (Investigation No.: 332–503)
(Nov. 18, 2009). Mr. Quesenberry
testified ‘‘through the course of many
years of hard negotiation on this issue,
plus several months of hard work on the
legislative language, this issue never
came up, so I can tell you that it was
not the intent of the negotiator that
finishing would be allowed from
outside of the United States at the
Dominican Republic. This was designed
to be a program between those two
countries.’’
Without any legislative history,
OTEXA considered the interpretation of
‘‘wholly formed’’ in light of other
programs it administers. The CBTPA,
which was enacted pursuant to the
Trade and Development Act of 2000
(Pub. L. 106–200, 114 Stat. 251, 2766),
included the phrase ‘‘wholly formed,’’
but did not define that term. In
implementing the CBTPA, CBP
promulgated regulations (United StatesCaribbean Basin Trade Partnership Act
and Caribbean Basin Innitiative, 65 FR
59650, October 5, 2000) which did not
require finishing, dyeing, or printing to
occur within the region for preferential
treatment. Subsequent to the
promulgation of the regulations
implementing CBTPA, Congress enacted
the Trade Act of 2002 (Pub. L. 107–210),
which amended and extended the
CBTPA and established the ATPDEA. In
that Act, Congress amended the CBTPA
and provided in the ATPDEA the
wholly formed requirement that all
dyeing, printing and finishing of fabrics
be carried out in the United States (Pub.
L. 107–210, 116 Stat, 1035–1036):
Apparel articles entered on or after
September 1, 2002, shall qualify under the
preceding sentence only if all dyeing,
printing, and finishing of the fabrics from
which the articles are assembled, if the
fabrics are knit fabrics, is carried out in the
United States. Apparel articles entered on or
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after September 1, 2002, shall qualify under
the first sentence of this clause only if all
dyeing, printing, and finishing of the fabrics
from which the articles are assembled, if the
fabrics are woven fabrics, is carried out in the
United States.
Further, the CAFTA–DR FTA uses the
term ‘‘wholly formed’’ in two provisions,
footnote 6 to Article 3.25(8) and
footnote 7 to Article 3.26. In both
provisions, the definition of ‘‘wholly
formed’’ includes dyeing and finishing.
Although the terminology is used in
different instances in the DREIAP
Implementation Act and the CAFTA–DR
FTA, OTEXA considers it persuasive in
defining the term here.
OTEXA agrees with the commentators
who stated that the dyeing and finishing
stages impart distinct characteristics
which only then make the fabric
suitable for a specific apparel
application; i.e., intended for
production of apparel in the Dominican
Republic as stated in the DREIAP
Implementation Act. Unfinished fabric
can be used for other applications
beyond the assembly of trousers and
similar garments covered by DREIAP.
OTEXA does not believe that dyeing
and finishing outside the United States
would preserve or promote the use of
United States fabrics as intended by the
DREIAP. Furthermore, in OTEXA’s
experience administering trade
preference programs, OTEXA
understands that often over 50 percent
of the value of a fabric is attributable to
the dyeing, finishing and printing
process. Thus, allowing offshore
finishing undercuts critical benefits to
the United States textile sector, contrary
to an aim of the DREIAP.
OTEXA is also mindful of the manner
in which Congress directed it to
administer the program. Permitting
finishing outside the United States prior
to the fabric being shipped to the
Dominican Republic would potentially
involve one or more countries and
companies involved, and it would be
difficult if not impossible to verify that
the fabric was eventually exported to
the Dominican Republic from the
United States for cutting and assembly.
This is a critical determination for fabric
to qualify for duty free importation into
the United States. See Sections 4 and 6
of the Interim Procedures, 74 FR at
3565–66.
Based on the foregoing, OTEXA has
determined it will continue to interpret
the term ‘‘wholly formed’’ within the
definition of ‘‘qualifying woven fabric’’
to require that all production processes
and finishing operations, starting with
weaving and ending with a fabric ready
for cutting or assembly without further
E:\FR\FM\03AUN1.SGM
03AUN1
Federal Register / Vol. 75, No. 148 / Tuesday, August 3, 2010 / Notices
processing, took place in the United
States under the DREIAP.
Kim Glas,
Deputy Assistant Secretary, Office of Textiles
and Apparel.
[FR Doc. 2010–19065 Filed 8–2–10; 8:45 am]
BILLING CODE 3510–DS–P
DEPARTMENT OF COMMERCE
International Trade Administration
[A–423–808]
Stainless Steel Plate in Coils From
Belgium: Correction to Notice of Final
Results of Antidumping Duty
Administrative Review
Import Administration,
International Trade Administration,
Department of Commerce.
DATES: Effective Date: August 3, 2010.
FOR FURTHER INFORMATION CONTACT: Joy
Zhang or George McMahon, AD/CVD
Operations, Office 3, Import
Administration, International Trade
Administration, U.S. Department of
Commerce, 14th Street and Constitution
Avenue, NW., Washington DC 20230;
telephone: (202) 482–1168 or (202) 482–
1167, respectively.
SUPPLEMENTARY INFORMATION:
erowe on DSK5CLS3C1PROD with NOTICES
AGENCY:
Correction
On October 19, 2009, the Department
of Commerce (‘‘the Department’’)
published in the Federal Register the
following notice: Stainless Steel Plate in
Coils From Belgium: Final Results of
Antidumping Duty Administrative
Review, 74 FR 53468 (October 19, 2009)
(‘‘Final Results’’). Subsequent to the
publication of the notice in the Federal
Register, we identified an inadvertent
error in the Final Results. The
Department made an error in the ‘‘Cash
Deposit Requirements’’ section of the
notice, by inadvertently including an
incorrect ‘‘all others’’ rate for exporters
and/or manufacturers not covered by
the review for which the Final Results
were published. Specifically, the ‘‘all
others’’ rate should have been listed as
8.54 percent pursuant to the
implementation of the findings of the
World Trade Organization (‘‘WTO’’)
Panel in US—Zeroing (EC). See
Implementation of the Findings of the
WTO Panel in US—Zeroing (EC): Notice
of Determinations Under Section 129 of
the Uruguay Round Agreements Act and
Revocations and Partial Revocations of
Certain Antidumping Duty Orders, 72
FR 25261 (May 4, 2007). For reference,
below is the corrected paragraph
regarding the ‘‘all others’’ rate discussed
in the Final Results.
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14:41 Aug 02, 2010
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Cash Deposit Requirements
The following antidumping duty
deposit rates will be effective upon
publication of the final results of this
administrative review for all shipments
of stainless steel plate in coils (‘‘SSPC’’)
from Belgium entered, or withdrawn
from warehouse, for consumption on or
after the publication date of these final
results, as provided for by section
751(a)(1) of the Tariff Act of 1930, as
amended (‘‘the Act’’): (1) For AMS
Belgium, the cash deposit rate will be
the rate established in the final results
of this review; (2) if the exporter is not
a firm covered in this review, but was
covered in a previous review or the
original less-than-fair-value (‘‘LTFV’’)
investigation, the cash deposit rate will
continue to be the company-specific rate
established for the most recent period;
(3) if the exporter is not a firm covered
in this review, a prior review, or the
LTFV investigation, but the
manufacturer is, the cash deposit rate
will be the rate established for the most
recent period for the manufacturer of
the subject merchandise; and (4) if
neither the exporter nor the
manufacturer is a firm covered by this
review, a prior review, or the LTFV
investigation, the cash deposit rate will
be 8.54 percent ad valorem, the ‘‘allothers’’ rate established in the
implementation of the findings of the
WTO Panel in US—Zeroing (EC). See
Implementation of the Findings of the
WTO Panel in US—Zeroing (EC): Notice
of Determinations Under Section 129 of
the Uruguay Round Agreements Act and
Revocations and Partial Revocations of
Certain Antidumping Duty Orders, 72
FR 25261 (May 4, 2007). These cash
deposit rates shall remain in effect until
further notice.
Conclusion
The Department clarifies that the
‘‘Cash Deposit Requirements’’ section of
the Final Results inadvertently listed
the ‘‘all others’’ rate as 9.86 percent and
that the correct ‘‘all others’’ rate is 8.54
percent. The Department intends to
issue revised cash deposit instructions
to U.S. Customs and Border Protection
(CBP) for entries made during the period
of review of May 1, 2007, through April
30, 2008, which includes the corrected
‘‘all others’’ rate of 8.54 percent.
This notice is issued and published in
accordance with sections 751(a)(1) and
777(i)(1) of the Act.
Dated: July 27, 2010.
Paul Piquado,
Acting Deputy Assistant Secretary for Import
Administration.
[FR Doc. 2010–19064 Filed 8–2–10; 8:45 am]
BILLING CODE 3510–DS–P
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45605
DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric
Administration
RIN: 0648–XX96
Fisheries of the South Atlantic and
Gulf of Mexico; Southeast Data,
Assessment, and Review (SEDAR);
assessment webinar 5 for SEDAR 22
yellowedge grouper and tilefish.
National Marine Fisheries
Service (NMFS), National Oceanic and
Atmospheric Administration (NOAA),
Commerce.
ACTION: Notice of SEDAR 22 Gulf of
Mexico yellowedge grouper and tilefish
assessment webinar 5.
AGENCY:
The SEDAR 22 assessments of
the Gulf of Mexico stocks of yellowedge
grouper and tilefish will consist of a
series of workshops and webinars: a
Data Workshop, a series of Assessment
webinars, and a Review Workshop. See
SUPPLEMENTARY INFORMATION.
DATES: The fifth SEDAR 22 Assessment
Process webinar will be held on
Monday, August 23, 2010 from 10 a.m.
until approximately 2 p.m. (EDT). The
established times may be adjusted as
necessary to accommodate the timely
completion of discussion relevant to the
assessment process. Such adjustments
may result in the meeting being
extended from, or completed prior to
the time established by this notice.
ADDRESSES: The meeting will be held
via webinar. The webinar is open to
members of the public. Those interested
in participating should contact Julie
Neer at SEDAR (See FOR FURTHER
INFORMATION CONTACT) to request an
invitation providing webinar access
information.
A listening station will be available at
the Gulf of Mexico Fishery Management
Council office located at 2203 N Lois
Avenue, Suite 1100, Tampa, FL 33607.
Those interested in participating via the
listening station should contact Julie A.
Neer at SEDAR (See FOR FURTHER
INFORMATION CONTACT) at least 1 day
prior to the webinar.
FOR FURTHER INFORMATION CONTACT: Julie
A Neer, SEDAR Coordinator, 4055 Faber
Place, Suite 201, North Charleston, SC
29405; phone: (843) 571–4366; e-mail:
Julie.neer@safmc.net
SUMMARY:
The Gulf
of Mexico, South Atlantic, and
Caribbean Fishery Management
Councils, in conjunction with NOAA
Fisheries and the Atlantic and Gulf
States Marine Fisheries Commissions
have implemented the Southeast Data,
Assessment and Review (SEDAR)
SUPPLEMENTARY INFORMATION:
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Agencies
[Federal Register Volume 75, Number 148 (Tuesday, August 3, 2010)]
[Notices]
[Pages 45603-45605]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-19065]
=======================================================================
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DEPARTMENT OF COMMERCE
International Trade Administration
Determination by the Department of Commerce on the Wholly Formed
Requirement for Qualifying Woven Fabric Under the Dominican Republic
Earned Import Allowance Program
July 29, 2010.
AGENCY: Department of Commerce, International Trade Administration.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: The Department of Commerce has determined to maintain the
current interpretation of the wholly formed requirement of qualifying
woven fabric under the Dominican Republic Earned Import Allowance
Program (DREIAP).
FOR FURTHER INFORMATION CONTACT: Robert Carrigg, Office of Textiles and
Apparel, Import Administration, U.S. Department of Commerce, (202) 482-
2573.
SUPPLEMENTARY INFORMATION:
Authority: Section 2(a) of the Andean Trade Preference Extension
Act of 2008 (``ATPEA''); Section 404(b)(2)(H) of the Dominican
Republic-Central America-United States Free Trade Agreement (``CAFTA-DR
FTA'') Implementation Act, as amended; Imports of Certain Apparel
Articles: Interim Procedures for the Implementation of the Earned
Import Allowance Program Established Under the Andean Trade Preference
Extension Act of 2008 (74 FR 3563, published January 21, 2009)
(``Interim Procedures'').
DATES: Effective Date: August 3, 2010.
Background
On December 1, 2008, the Department of Commerce implemented
provisions under the Andean Trade Preference Extension Act of 2008
(Pub. L. 110-436, 122 Stat. 4976) (ATPEA or implementing legislation).
Section 2 of the ATPEA amends Title IV of the CAFTA-DR FTA
Implementation Act (Pub. L. 109-53; 119 Stat. 495). Specifically, Title
IV of the CAFTA-DR FTA Implementation Act is amended by adding Section
404, creating a benefit for eligible apparel articles wholly assembled
in the Dominican Republic that meet the requirements for a ``2 for 1''
earned import allowance. Section 2 of the ATPEA requires the Secretary
of Commerce to establish a program to provide earned import allowance
certificates to any producer or entity controlling production of
eligible apparel articles in the Dominican Republic, such that apparel
wholly assembled in the Dominican Republic from fabric or yarns,
regardless of their source, and imported directly from the Dominican
Republic, may enter the United States duty-free, pursuant to the
satisfaction of the terms governing issuance of the earned import
allowance certificate. The Secretary of Commerce has delegated his
authority under the CAFTA-DR FTA Implementation Act to implement and
administer the Earned Import Allowance Program to the International
Trade Administration's Office of Textiles and Apparel (``OTEXA'').
On January 21, 2009, OTEXA published interim procedures, 74 FR
3563, implementing Section 2 of the ATPEA. These procedures set forth
the provisions OTEXA will follow in implementing the DREIAP. In
accordance with these procedures, OTEXA issues certificates to
qualifying apparel producers to accompany imports of eligible apparel
articles wholly formed in the Dominican Republic and exported from the
Dominican Republic. Such certificates will be issued as long as there
is a sufficient balance of square meter equivalents available as a
result of the purchase of qualifying woven fabric. ``Qualifying woven
fabric'' is defined in Section 2 of the ATPEA and in OTEXA's interim
procedures as ``woven fabric of cotton wholly formed in the United
States from yarns wholly formed in the United States'' and intended for
production of apparel in the Dominican Republic. See Section 2(e) of
the Interim Procedures; Section 404(c)(4) of the CAFTA-DR FTA
Implementation Act, as amended by Section 2 of the ATPEA. Neither the
ATPEA nor the interim procedures define the term ``wholly formed'' as
it is used in the definition of ``qualifying woven fabric.''
OTEXA received inquiries regarding the interpretation of ``wholly
formed'' as a requirement under the definition of ``qualifying woven
fabric.'' Accordingly, on April 3, 2009 (74 FR 15254), OTEXA requested
public comment on the intended meaning of the ``wholly formed''
requirement in the definition of ``qualifying woven fabric'' for the
purposes of the DREIAP. In that request for public comment, OTEXA
explained that it ``currently interprets `wholly formed' within the
definition of `qualifying woven fabric' to require that all production
processes and finishing operations, starting with weaving and ending
with a fabric ready for cutting or assembly without further processing,
take place in the United States.'' Id., 74 FR at 15255.
OTEXA received ten comments and has carefully analyzed the points
raised in each submission. These comments are available on OTEXA's Web
site at https://web.ita.doc.gov/tacgi/otexa_dr_eiap_publiccomments.nsf/504ca249c786e20f85256284006da7ab?OpenView&Start=1.
Department officials have also discussed this matter on several
occasions with interested stakeholders to ensure that all points have
been considered.
Commentators that support OTEXA's current interpretation contend
that the DREIAP was intended to improve the competitiveness of
Dominican apparel producers and create new export opportunities for
United States manufacturers of qualifying fabrics. These commentators
suggest that from the beginning, it was clear that the intent was to
base the program on the delivery of qualifying fabric ready for cutting
and sewing into trousers. There was never any discussion of permitting
greige fabric (raw fabric that has yet to be bleached or dyed) to be
shipped to another country for finishing and allowing such fabric to
qualify for benefits under the program because it was understood that
support from United States industry was dependent on the requirement
that fabric be produced and finished in the United States so that it
would be ready for cutting and sewing upon arrival in the Dominican
Republic. These commentators argue that effective enforcement of the
program would be more difficult if third countries were able to
participate as finishers. They also contend that the dyeing and
finishing stage imparts distinct characteristics that only then make
the fabric suitable for a specific apparel application as envisaged by
the legislation. Unfinished fabric can be used for applications other
than the assembly of trousers and similar garments. The commentators
contend that although the program was enacted as an amendment to the
CAFTA-DR FTA Implementation Act, it could have been implemented as a
stand-alone bill or as an amendment to other relevant legislation.
These commentators suggest that the connection between the program and
the vehicle to which it was attached is one of legislative convenience.
These commentators state that at no time was there an expression
[[Page 45604]]
to treat the program as other than a preferential program and at no
time was it contemplated that the finishing of qualifying fabrics could
take place outside the United States.
Furthermore, these commentators state that allowing finishing
outside the United States does not preserve or promote the use of
United States fabrics as intended by the program. Lastly, these
commentators contend that there is more than sufficient capacity in the
United States to dye, print, and finish the amount of fabric required
by Dominican Republic apparel manufacturers for qualification under the
program.
Commentators who disagree with OTEXA's current interpretation
assert that the term ``wholly formed'' as used in the DREIAP does not
require the fabric to be dyed and finished in the United States, and
that such an interpretation negates the benefits of the program. These
commentators contend that this issue was never addressed during the
discussions leading to the creation of the program. As such, they
contend that OTEXA's current interpretation was not contemplated in the
drafting of the legislation and is not required under the express terms
of the legislation. They argue that Customs and Border Protection
(``CBP'') interpreted the term ``wholly formed'' when used in the
Caribbean Basin Trade Preference Act (``CBTPA'') of 2000 (Pub. L. 106-
200, 114 Stat, 251, 2766) as not requiring dyeing and finishing. These
commentators contend that Congress did not amend the definition of
``wholly formed'' in the Trade Act of 2002 (Pub. L. 107-210), but only
added a new requirement. These commentators state that because the
DREIAP is not an amendment to the CAFTA-DR FTA, the requirements for
dyeing and finishing specified in two footnotes in that agreement do
not apply to the term in this program. They contend that there is no
requirement to directly ship qualifying fabric to the Dominican
Republic; therefore, dyeing and finishing of United States greige
fabric is not precluded. They argue that OTEXA's interpretation is
inconsistent with other similar programs. Finally, these commentators
argue that originating apparel under free trade agreements need not be
dyed or finished by the parties.
Analysis and Determination
After careful consideration of the interested party comments, OTEXA
has determined it will continue to interpret ``wholly formed'' within
the definition of ``qualifying woven fabric'' to require that all
production processes and finishing operations, starting with weaving
and ending with a fabric ready for cutting or assembly without further
processing, take place in the United States under the DREIAP.
Neither the ATPEA nor the interim procedures define the term
``wholly formed'' as it is used in the definition of ``qualifying woven
fabric.'' Additionally, there is no legislative history regarding this
term as it is used in this program. Although not controlling, OTEXA
considered testimony given by former Special Textile Negotiator for the
United States Trade Representative, Scott Quesenberry. See Testimony
before the United States International Trade Commission on the matter
of the Earned Import Allowance Program: Evaluation of the Effectiveness
of the Program for Certain Apparel from the Dominican Republic
(Investigation No.: 332-503) (Nov. 18, 2009). Mr. Quesenberry testified
``through the course of many years of hard negotiation on this issue,
plus several months of hard work on the legislative language, this
issue never came up, so I can tell you that it was not the intent of
the negotiator that finishing would be allowed from outside of the
United States at the Dominican Republic. This was designed to be a
program between those two countries.''
Without any legislative history, OTEXA considered the
interpretation of ``wholly formed'' in light of other programs it
administers. The CBTPA, which was enacted pursuant to the Trade and
Development Act of 2000 (Pub. L. 106-200, 114 Stat. 251, 2766),
included the phrase ``wholly formed,'' but did not define that term. In
implementing the CBTPA, CBP promulgated regulations (United States-
Caribbean Basin Trade Partnership Act and Caribbean Basin Innitiative,
65 FR 59650, October 5, 2000) which did not require finishing, dyeing,
or printing to occur within the region for preferential treatment.
Subsequent to the promulgation of the regulations implementing CBTPA,
Congress enacted the Trade Act of 2002 (Pub. L. 107-210), which amended
and extended the CBTPA and established the ATPDEA. In that Act,
Congress amended the CBTPA and provided in the ATPDEA the wholly formed
requirement that all dyeing, printing and finishing of fabrics be
carried out in the United States (Pub. L. 107-210, 116 Stat, 1035-
1036):
Apparel articles entered on or after September 1, 2002, shall
qualify under the preceding sentence only if all dyeing, printing,
and finishing of the fabrics from which the articles are assembled,
if the fabrics are knit fabrics, is carried out in the United
States. Apparel articles entered on or after September 1, 2002,
shall qualify under the first sentence of this clause only if all
dyeing, printing, and finishing of the fabrics from which the
articles are assembled, if the fabrics are woven fabrics, is carried
out in the United States.
Further, the CAFTA-DR FTA uses the term ``wholly formed'' in two
provisions, footnote 6 to Article 3.25(8) and footnote 7 to Article
3.26. In both provisions, the definition of ``wholly formed'' includes
dyeing and finishing. Although the terminology is used in different
instances in the DREIAP Implementation Act and the CAFTA-DR FTA, OTEXA
considers it persuasive in defining the term here.
OTEXA agrees with the commentators who stated that the dyeing and
finishing stages impart distinct characteristics which only then make
the fabric suitable for a specific apparel application; i.e., intended
for production of apparel in the Dominican Republic as stated in the
DREIAP Implementation Act. Unfinished fabric can be used for other
applications beyond the assembly of trousers and similar garments
covered by DREIAP. OTEXA does not believe that dyeing and finishing
outside the United States would preserve or promote the use of United
States fabrics as intended by the DREIAP. Furthermore, in OTEXA's
experience administering trade preference programs, OTEXA understands
that often over 50 percent of the value of a fabric is attributable to
the dyeing, finishing and printing process. Thus, allowing offshore
finishing undercuts critical benefits to the United States textile
sector, contrary to an aim of the DREIAP.
OTEXA is also mindful of the manner in which Congress directed it
to administer the program. Permitting finishing outside the United
States prior to the fabric being shipped to the Dominican Republic
would potentially involve one or more countries and companies involved,
and it would be difficult if not impossible to verify that the fabric
was eventually exported to the Dominican Republic from the United
States for cutting and assembly. This is a critical determination for
fabric to qualify for duty free importation into the United States. See
Sections 4 and 6 of the Interim Procedures, 74 FR at 3565-66.
Based on the foregoing, OTEXA has determined it will continue to
interpret the term ``wholly formed'' within the definition of
``qualifying woven fabric'' to require that all production processes
and finishing operations, starting with weaving and ending with a
fabric ready for cutting or assembly without further
[[Page 45605]]
processing, took place in the United States under the DREIAP.
Kim Glas,
Deputy Assistant Secretary, Office of Textiles and Apparel.
[FR Doc. 2010-19065 Filed 8-2-10; 8:45 am]
BILLING CODE 3510-DS-P