APEP Letter
July 17, 2024
Docket Number: USTR-2024-0009
To: Laura Buffo, Chair of the Trade Policy Staff Committee Office of the United States Trade Representative
Submitted by: Rachel Kibbe, CEO, ACT (American Circular Textiles Group)
ACT Members as of July 17, 2024: The RealReal - Rent The Runway - ThredUp - Arrive - Fashionphile - H&M - Reformation - Evrnu - -Kreussler- Supercircle - Circ - Debrand - Retold Recycling - Sortile - Trove - America’s Best Cleaners - Charming Trim - Project Repat - Check Sammy - Reju Affiliates: Recurate - Tersus - Returnity - unspun - alternew - Madison Cline - Circularly - FABSCRAP - Return to Vendor
Dear Ms. Buffo,
ACT (American Circular Textiles) represents thirty leading companies in the United States with interests and operations in the textiles circular economy, and thousands of jobs in American communities. We are a first-of-its-kind coalition of organizations aimed at identifying and supporting circular textile policy opportunities that will create sustainable jobs, bolster American business, educate consumers, and protect our supply chains and environment. ACT represents a new sector and business model that transitions from a linear “take make waste” business model, to one focused on growth through the reuse and recycling of our limited planetary resources. ACT membership includes some of the leading organizations driving textile circularity in the United States through facilitating reuse, recycling, rental, repair, technology and innovation.
We write in response to USTR’s request for public comments on U.S. interests and priorities, in order to develop trade-related lines of effort in the track of the Americas Partnership for Economic Prosperity (APEP), and to express how The Americas Trade and Investment Act (The ‘Americas Act’) is a means to address these efforts in full. We applaud the Biden Administration’s commitment to the APEP, the APEP member countries, and for capitalizing on the economic, labor, environmental, and geopolitical cohesion of the regions. The Americas Act provides bipartisan durability and much-needed policy incentives adhering to the vision within APEP.
Based on the national business interests that we represent, we understand the urgency of deepening economic collaboration and integration of APEP trade relationships in the Western Hemisphere firsthand. Unfortunately, for APEP to work it requires industry incentives. APEP presently offers no financial tools for industry support for deepening trade relationships, which, in addition to harmonization, will require complementary market access and incentives, including tax and investment catalysts.
The Americas Act, a bipartisan, bicameral bill, not only fully addresses the needed trade harmonization between APEP countries, but also includes the necessary financial tools which to date have been unaddressed by APEP. Provisions in the bill include support for industry growth and workforce 1 development in the Western Hemisphere, thereby creating a roadmap to pursue the flexible and goal-oriented regional and economic development agenda outlined by the partnership, along with the financial mechanisms urgently needed to bolster national and Western Hemisphere interests in decarbonized manufacturing and trade alike. Countries like China have seized the moment in focusing on clean energy and supply side manufacturing, with a sustainable vision to supply the world, and are well on their way to capturing these opportunities wholeheartedly, while the United States is being left behind. The Inflation Reduction Act (IRA) attempts to counter China’s and East Asia’s manufacturing and supply chain dominance but certain sectors and industries were excluded, like textiles. Furthermore, the IRA is rightfully domestically focused but the Americas Act can complement the vision by tackling the manufacturing renaissance with a regional focus.
Specific to textiles, the provisions whose development our group supported in the Americas Act, include the needed investments for our industry to compete globally from within the United States, including a 15% tax break for textile reuse and recycling related businesses, and $14B of grants and loans for infrastructure, reverse logistics, manufacturing, innovation and public education. As such, the trade priorities identified in your partnership are more holistically addressed through the meaningful financial levers and market incentives in this legislation, tools that were also lacking in the IRA.
The cross cutting priorities of the APEP partnership are also addressed in Americas Act. These priorities, which you have indicated, include: regional competitiveness, shared prosperity and good governance, sustainable infrastructure, climate and environmental protection, local labor empowerment, and promotion of healthy communities. By way of example, our provisions would bolster national thrift stores, repair and rental businesses, and textile manufacturers, while also catalyzing innovation, jobs and infrastructure for new technologies like textile recycling.
While the Americas Act is not specific to textiles alone, the examples we have provided are echoed throughout the bill for all industries with an interest in APEP. Finally, as APEP is currently an executive action that could be overturned with the next administration, we require durable complementary trade policy that is outlined in Americas Act. The policies within the Americas Act, in concert with the vision of APEP, will ensure the United States and our South and Latin America allies are charting a sustainable economic path that complements labor growth while respecting our environment.
We thank you in advance for your attention to our comments and look forward to a response.
Sincerely,
Rachel Kibbe
