Fashion & Apparel · For mid-market and enterprise importers
Get every style through U.S. customs before the season starts.
Greenwich Mercantile works with mid-size and large European and U.S. fashion brands that ship seasonal collections into the U.S. from makers in Asia and Europe, for example in Italy, Portugal and Spain. Fashion runs on dates. A container held at the port for missing fibre content, origin or cotton-tracing evidence can miss the drop it was bought for. We get that evidence in place before the goods ship, and use the same record to pay the lowest duty the law allows on every style.
Why apparel gets stuck at the border.
Clothing is one of the most document-heavy categories CBP sees. The duty on a garment depends on details that live with the supplier, not the brand: what the fabric is made of by weight, whether it is knitted or woven, who it is cut for, and where the fabric was formed or the garment assembled. When that evidence is missing or does not match the invoice, the entry stops.
The most common causes we see are simple and preventable:
- Fibre content that does not match. The invoice says one blend, the label says another, and the tariff code follows neither.
- Origin nobody can prove. Fabric woven in one country, cut and sewn in another. U.S. textile origin rules decide which one counts, and CBP will ask.
- Cotton that cannot be traced. Goods with cotton from Xinjiang are presumed made with forced labour and can be detained until the importer proves otherwise, back to the fibre.
- Labelling gaps. Fibre content, country of origin and the manufacturer identity required on the garment label.
Each one is a question about paperwork, not about the clothes. That is why it can be fixed before the goods leave the factory.
What we do for fashion brands.
| When | What we do | What it is worth |
|---|---|---|
| Before the purchase order | Landed cost by style and supplier: duty, fees and delivered cost, including the country-specific measures that apply to apparel this season. | You see which factory is really cheapest before the order is placed, not when the duty bill arrives. |
| Before the goods ship | Invoice, packing list, fibre content, origin and cotton-tracing records checked against each other. Anything missing goes back to the supplier while the goods are still at the factory. | Stock arrives in time for the drop. Nobody on your team spends launch week chasing a mill for a certificate. |
| Every style, every season | One record per style: fibre, construction, origin and value at each step. Reused on every reorder and every new season. | The broker supports the correct duty treatment instead of the default one, and CBP questions are answered from the file. |
Every duty position is reviewed and signed by a licensed U.S. customs broker: our broker partner, or your existing broker working from the same record.
Where the duty savings are in apparel.
Apparel carries some of the highest duty rates in the U.S. tariff schedule, so small corrections add up across a season. The savings usually come from getting the record right, not from finding a loophole:
- Correct classification. The fibre that is chief by weight, knit versus woven, and garment construction all move the rate. Many programmes pay the rate on a default code nobody has checked in years.
- First sale valuation. Where a brand buys through a trading company or agent, duty can in some cases be declared on the price the factory charged the middleman rather than the price you paid. It needs a documented sale for export to the U.S., and a broker who will stand behind it.
- Origin planning. Moving a sewing stage can change the country of origin, and with it the duty. Model it before you move production, not after.
Apart from the general (MFN) rates in the illustrative example below, we do not quote rates on this page. The measures on apparel have changed several times this year, and a stale number is worse than none. See our current Section 301 apparel guide and duty rates for clothing.
An illustrative duty example: one blouse, two fiber blends.
Illustrative example. A fashion brand orders 1,000 women's knitted blouses for a seasonal collection at $15.00 each, an entered value of $15,000. Under the textile notes of the U.S. Harmonized Tariff Schedule (HTS), a garment made of blended fibers is classified by the fiber that predominates by weight, so the fiber content of the fabric sets the duty rate.
A blouse knitted from 60% cotton and 40% polyester is classified as a cotton garment under HTS 6106.10.00, general rate 19.7%: $15,000 × 19.7% = $2,955 in duty.
The same blouse knitted from 40% cotton and 60% polyester is classified as a man-made fiber garment under HTS 6106.20.20, general rate 32%: $15,000 × 32% = $4,800 in duty.
Switching the blend from mostly cotton to mostly polyester adds $1,845 of duty per 1,000 blouses at the general rates alone. The fiber content on the mill's test report, the invoice and the garment label need to agree before the goods ship.
The example uses only the general (MFN) rates returned by the USITC Harmonized Tariff Schedule on 2 October 2026. Additional duties in force on the entry date, such as country-specific tariffs, must be confirmed by a licensed broker.
For enterprise fashion programmes: protect margin season by season.
At enterprise scale the question is rarely one style. It is whether tariff mitigation already built into this year's margin plan is actually happening lane by lane, and whether sourcing moves are judged on landed cost or on the factory price.
| The executive question | Which lanes are behind the tariff mitigation in this year's margin plan, and who owns that number? |
|---|---|
| What decides it | Classification by fibre and construction, origin under the textile rules of origin (19 CFR 102.21), first sale valuation where the buying structure supports it, and cotton tracing for forced-labour rules. |
| How it is proved | One shipping lane, 30 days. We check that lane's documents before entry while your current broker keeps filing, and a licensed U.S. customs broker reviews every finding. |
| Agreed in writing first | The success threshold, the executive who owns the readout and the condition for stopping. No outcome is promised before the lane has been checked. |
This is the proof, not the whole engagement. What we hope to earn afterwards is the next lanes, funded by the same owner, if the first one shows real findings.
The programmes we are built for share all five of these. Under dates and complexity, one of the listed examples is enough:
- Where you are based. Headquartered in the U.S. or Europe and importing into the U.S.
- What you sell. Fashion, beauty and cosmetics, food, or consumer goods.
- Scale. Around 5,000 or more containers a year, hundreds of SKUs and international suppliers.
- Dates that cost money. Seasonal launches, shelf life or retailer commitments.
- Complexity. FDA or USDA requirements, anti-dumping or countervailing duties, repair-and-return, or tariff planning across several origins.
If your programme looks different, ask anyway. We will tell you plainly in the first conversation whether there is work worth doing.
The same approach for other categories:
How the first piece of work is scoped.
One product category or one sourcing country. A defined output, a fixed fee and a delivery date. You keep the output whether or not anything follows it.
Before that, 20 minutes to find out whether there is a problem worth pricing: which styles cause the most questions at entry, where supplier paperwork slows a shipment down, and what a late container costs you in a peak season.
Questions, answered directly.
What do clothing importers need to clear U.S. customs?
A commercial invoice and packing list that agree with each other, plus evidence of fibre content by weight, how the garment is made (knit or woven), who it is for, and where the fabric was formed and the garment assembled. Cotton goods may also need supply-chain tracing back to the fibre. The garment label must show fibre content, country of origin and the manufacturer or importer identity.
What does the Textile Fiber Products Identification Act require?
It is enforced by the Federal Trade Commission and requires most textile and apparel products sold in the U.S. to carry a label showing the generic fibre content by percentage, the country of origin, and the name or registered identification number (RN) of the manufacturer or another business handling the product. It is a labelling rule, separate from the customs entry, but a mismatch between the label and the invoice is a common reason CBP asks questions.
How is country of origin decided for clothing?
U.S. textile origin rules (19 CFR 102.21) decide it, and for many garments origin turns on where the garment was wholly assembled or where the fabric was formed rather than where the brand is based or the goods shipped from. The answer can change the duty and the labelling, so it should be settled with evidence before the goods ship.
Can Greenwich lower the duty we pay on apparel?
Often, by making sure each style is classified and valued correctly and that the record supports it: correct fibre and construction classification, first sale valuation where the buying structure allows it, and origin planning before production moves. Any saving depends on your actual products and documents, and every duty position is reviewed by a licensed U.S. customs broker.
Can you guarantee our shipments will not be held?
No. CBP can examine or detain any shipment. What we prevent is the avoidable kind of hold: the one caused by missing or inconsistent paperwork. That is the most common kind, and the easiest to fix before the goods leave the factory.
Who files the entry with U.S. Customs?
A licensed U.S. customs broker reviews and files every entry under your power of attorney: one of our partner brokers, or your existing broker working from the same record. Greenwich does the customs work behind each entry with AI: the landed-cost model, the pre-entry document pack and the product record.
We already have a customs broker. How would a first engagement work?
Greenwich checks one shipping lane's documents before entry for 30 days while your current broker keeps filing. A licensed U.S. customs broker reviews every finding. The success threshold, the executive who owns the readout and the condition for stopping are agreed in writing before the lane starts. If you have no record yet of holds or exams on that lane, the first weeks establish one.
Sources and limits
- FTC: Textile and Wool Acts labelling requirements
- 19 CFR 102.21: textile rules of origin
- CBP: Uyghur Forced Labor Prevention Act
- CBP: Reasonable Care
- USITC HTS 6106.10.00: women's knitted blouses and shirts of cotton (general rate 19.7%)
- USITC HTS 6106.20.20: women's knitted blouses and shirts of man-made fibers, other (general rate 32%)
- USITC HTS Section XI notes (chapter 50 file): blended textiles classified by the fiber that predominates by weight
- CBP: antidumping and countervailing duties
Sources support the stated context. They are not an endorsement of Greenwich and not a determination on your shipments. Nothing on this page is a duty quotation.
Twenty minutes with whoever owns your U.S. imports.
Tell us which styles, suppliers and seasons matter most. We will tell you honestly whether there is anything worth doing.
Or write to cameron@greenwich-mercantile.com.