Third Quarter 2002 Legislative Update
(With links for more detailed information)
Members of Congress from both parties are now
firmly focused on the November 5 mid-term elections, which could determine
control of either or both chambers. At
this point, the number of close races makes it impossible to determine if the
Democrats will lose control of the Senate or if the Republican will lose
control of the House.
Although both chambers remain closely divided,
Congress has been surprisingly active in passing legislation. So far this session, Congress managed to
compile a substantial record passing new laws to reduce
individual taxes, reform education, respond to the 9/11 terrorist attacks,
strengthen campaign finance laws, promote trade and bring about better
corporate accountability.
Nevertheless, there are a number of pending items that still need to be addressed this year. Because of the abbreviated time during September and early October, Congress is all but guaranteed to return for a post-election lame duck session to complete its business. Lame duck sessions create an unusual dynamic since they include Members of Congress who are still entitled to vote even though they are no longer accountable to their constituents.
Both chambers are now working to complete action on the annual spending measures. Although the full House has approved only five and the Senate has only approved three FY 2003 appropriations bills funding various Federal Departments and agencies by the August recess, the Senate Appropriations Committee has approved all 13 bills funding all parts of the U.S. government. With Congress returning in early September, it is focusing considerable effort into getting as many of these passed before the beginning of the next Fiscal Year on October 1, 2002.
A proposal to create a new Department of Homeland Security is also likely to move this year, although it is currently stalled in the Senate over a civil service dispute. Other priorities for action when Congress returns this fall are pension reform legislation (inspire in part by the Enron scandal) and laws to discourage U.S. companies to escape taxation by moving abroad. In addition, a number of bills that are close to final action – such as a bankruptcy reform measure, a terrorism insurance subsidy initiative, an energy package, and a long-stalled election reform proposal – could also be completed this year. On the other hand, several high profile initiatives – such as the patients’ bill of rights or the prescription drug benefit for Medicare – are probably so mired in partisan rhetoric that further action is unlikely.
In this environment, AAFA is tracking a number of issues relating to the apparel and footwear industries, including:
·
International
trade
·
Government
contracting
·
Labor
·
Regulatory
matters
Recent developments of note on some of these issues include:
International Trade
1.
Preferential Trade Programs: On August 6, 2002,
President George W. Bush signed into law the Trade Act of 2002 (PL
107-210), which authorizes a new trade preference program for the Andean
region (Andean Trade Promotion and Drug Eradication Act -- ATPDEA) and also
makes needed corrections and enhancements to Caribbean Basin
Trade Partnership Act (CBTPA) and the African Growth and
Opportunity Act (AGOA) legislation that was passed in May 2000. The package also contains a five-year
renewal of the Generalized System of Preferences (GSP), which affects some sewn
products but not apparel or footwear.
The Administration is now working to promulgate draft regulations and
implementing documents for the ATPDEA and finalize regulations for the existing
CBTPA and AGOA programs. A dispute that
had delayed these regulations – over whether U.S. formed fabrics (for the CBTPA
and the ATPDEA) should be dyed, printed, and finished in the United States –
was resolved when these restrictions were incorporated in a supplemental
spending bill (HR
4775 - PL 107-206) and the Trade Act of 2002. AAFA
applauds enactment of the Africa, Caribbean Basin, and Andean trade enhancement
legislation and is working closely with Administration officials responsible
for implementation to achieve the most liberal interpretation as well as
legislative improvements.
2. Enactment of renewed “fast track” trade promotion authority (TPA): With approval of the Trade Act of 2002 (PL 107-210), President Bush also signed into law renewal of fast track trade promotion authority. This legislation simultaneously instructs U.S. trade negotiators and provides an “amendment-free” environment for congressional consultation and consideration of trade agreements. Among other things, TPA lays out negotiating objectives for labor rights, textile and apparel trade, and trade remedy principles that should be included in future trade agreements. Final passage came in the House on July 27, 2002 with a vote of 215 to 212 and in the Senate on August 1, 2002 with a vote of 64 to 34. AAFA applauded enactment of TPA as a key tool in opening markets for U.S. branded products.
3. Free Trade Area of the Americas: With enactment of TPA, the Administration can now press ahead with negotiations on the evolving Free Trade Area of the Americas (FTAA), which was promoted by President Bush during the Summit of the Americas conference in Quebec City in April 2001. Trade negotiators for the 34 democracies in the hemisphere have made considerable progress in developing a draft text of an agreement that would drop trade and investment barriers across North and South America. Negotiators are now working to meet a series of deadlines culminating in the conclusion of negotiations by January 2005 with full implementation occurring 12 months later. AAFA supports a well-negotiated and balanced FTAA.
4. Wool tariff reduction implementation: In May 2000, Congress enacted legislation to provide relief for U.S. suit makers for their imports of fine worsted wool. As part of the Trade Act of 2002 (PL 107-210), Congress made a series of enhancements to the original program. All told, this relief involves significant duty refunds and lower duties for a certain quantity of worsted wool fabric imports. AAFA applauds enactment of the legislation to correct the wool tariff inversion and is working with officials in the Administration to ensure the timely implementation of the duty refund program and the reduction in tariff rates.
5.
Trade Adjustment Assistance: The
TAA program provides training and unemployment assistance for workers who have
been displaced because of trade. As
part of the Trade Act of 2002 (PL
107-210), the TAA program has been reauthorized for six years and expanded
to include health benefits. AAFA applauds the
renewal of Trade Adjustment Assistance.
6. China Normal Trade Relations (NTR) and WTO Accession: China successfully acceded to the World Trade Organization (WTO) on December 11, 2001. Chinese accession also paved the way for the accession of Taiwan 20 days later. In recognition of China’s accession, the President proclaimed on December 27, 2001 that China now receives permanent normal trade relations and that imports from China are now accorded permanent Column 1 status in the Harmonized Tariff System (HTS). Attention now focuses on the specific terms of China’s accession package through which China and its trading partners made a number of specific commitments. Key elements of that accession package include:
· The agreement will end quotas on Chinese textile and apparel imports in Stage 4 on Dec. 31, 2004, when they end for all other WTO partners. Quotas on textile and apparel products covered in Stages 1 to 3 have already been removed. However, domestic industries can still petition for quotas to selectively restrain Chinese imports through a special textile and apparel safeguard, lasting until the end of 2008, and an overall 12-year product-specific safeguard, lasting until 2013. So far, no rules have been created for the textile and apparel safeguard while the ITC has promulgated draft, interim rules for the product-specific safeguard.
· Although China’s accession to the WTO does not reduce U.S. tariffs on Chinese apparel and footwear imports, it does reduce most duties on apparel and footwear imports into China. Most apparel duties will drop from about 35 percent to between 17 and 24 percent. Including other sectors, China will lower its overall average duties on imports to about 9 percent. Chinese footwear duties will be reduced from 25 percent to between 15 and 24 percent. Under the terms of the EU bilateral agreement on China’s WTO accession, some tariffs may drop further to 10 percent. These reductions would be available to all WTO countries, including the United States. The EU agreement also contains a timeline for the elimination of EU quotas on Chinese footwear. Finally, the bilateral accession agreement signed between Mexico and China guarantees Mexico the right to maintain punitive antidumping duties on Chinese apparel, textiles, and footwear for a period of six years.
· Other provisions of the agreement open up the Chinese market to provide more guaranteed market access, distribution and investment rights for foreigners.
AAFA supported accession of China to the WTO and the extension of permanent normal trade relations with China as a critical element of ensuring that China plays by the rules of international trade and is fairly treated by its WTO partners.
7. Customs/Port Security Issues: In the aftermath of 9/11 Congress has worked on a number of security related trade issues.
§ A Homeland Security bill (HR 5005), consolidating more than 20 agencies (including the U.S. Customs Service) into one Dept. of Homeland Security, cleared the House on July 26, 2002 by a vote of 295 to 132. A Senate version is expected to be considered soon after the Senate returns. Differences relating to civil service protections in the new Department have recently surfaced between Congressional Democrats and the White House, making it unlikely that the target date of the 9/11 anniversary will be met.
§ Several provisions were adopted as part of the Trade Act of 2002 (PL 107-210) in a title that also reauthorized U.S. Customs Service functions. Those provisions put more resources into the agency to respond to terrorism and strengthen border activities, including potential textile transshipment requirements. They also require the submission of advanced manifest information through a process developed in consultation with the trade.
§ Similar requirements are now pending in a conference on separate legislation (S. 1214) that also focuses on port security enhancements.
· Meanwhile, the Customs Service has announced a series of new customs and port security initiatives – including the Customs Trade Partnership Against Terrorism (C-TPAT) and the Container Security Initiative – focusing interdiction and investigation resources on higher risk containers.
· Finally, with the new security emphasis, attention still remains on computer automation to facilitate trade and provide state of the art risk assessment. The business community and the U.S. government are scrambling to ensure funding for the replacement system – known as the Automated Commercial Environment (ACE) – which comes with an estimated $1.4 billion price tag. In the FY 2002 Treasury Postal appropriations act (PL 107-67), Congress approved $300 million for this task (adding to the $258 million in automation funding approved during the previous year). For FY 2003, the House has so far recommended $316.9 million while the Senate Appropriations Committee has thus far recommended $312.9 million.
AAFA supports full funding of the ACE and commonsense measures to strengthen security without interdicting legitimate commerce.
8.
Miscellaneous User Fees: Several trade-related user fees have been discussed in Washington
over the past few months, including:
·
The Customs User Fee: Senate-passed legislation
(S. 1052)
that provides patients the right to sue their health care plans contains an
eight-year extension of the merchandise-processing fee. Although scheduled to expire in 2003, the
user fee would be extended as a way to offset costs of the health care
legislation to the tune of about $1 billion per year. By a vote of 46 to
52, Sen. Grassley (R-IA) was defeated in an effort to
strike this provision from the Senate bill.
Moreover, a House draft of the patients’ bill of rights (HR 2563)
contains the same provision. Such an
extension avoids the debate as to whether this fee should be extended or, if
extended, whether it should be applied only to Customs operations. Extension of the fee in this manner may also
trigger a WTO complaint. Other
initiatives to spend these funds included a provision offsetting the costs of
an expansion of Trade Adjustment Assistance (which was discarded) and a
proposal that had been suggested by Sen. Jean Carnahan (D-MO) to subsidize a plan
for displaced airline workers until 2005.
Similarly, Senator Ernest Hollings (D-SC) is proposing to “pay for” new
security enhancements at ports through a new security fee. AAFA opposes the extension
of the fee in any of these manners and is also opposed to the creation of new
user fees to fund security enhancements.
·
Cotton Fee: The U.S. Department of Agriculture
is now conducting a rule-making
exercise to determine whether it should hold a referendum on the
continuation of the cotton fee, which is used to fund the Department’s cotton
promotional and marketing program. A
special sign-up period, during which companies who import cotton products can
register their support for a referendum, concluded in August 2002. It is unclear whether there will be enough
support to stage a referendum. However,
it is worth noting that the cotton fee may be subject to further legal
challenges since a similar program was ruled unconstitutional by the U.S.
Supreme Court. AAFA supported
the holding of a referendum.
9.
Rising Protectionism: A strong U.S. dollar combined with
undervalued currencies among many trading partners fueled protectionist
sentiments in Congress. During the
first few months of 2002, the Bush Administration imposed punitive duties on
certain steel products from a number of countries and softwood lumber imports
from Canada. So far, the steel case has
provoked threats of retaliation by several countries, including the EU, which
has threatened to impose tariffs on a number of US-made textile, apparel, and
footwear exports. Despite these
threats, some in the textile industry have pointed to the steel case as a
possible precedent for similar action with respect to textiles and
apparel. AAFA believes
that new protectionist policies are not sustainable in the global rules-based
economy and that they would weaken U.S. economic prospects.
10. Bilateral Initiatives: A number of bilateral initiatives are underway in Washington. One bilateral free trade agreement has seen congressional action, while two more are under negotiation. In addition, President Bush has announced his intention to explore a free trade agreement with five countries of Central America and is widely expected to announce similar initiatives with a series of other countries, including Southern Africa.
·
Jordan: In late October 2000, the Clinton Administration and the Kingdom of Jordan signed a bilateral
free trade agreement. President
Bush enacted the legislation (PL 107-43)
on September 28, 2001. Textile and
apparel articles that meet the basic Breaux/Cardin rules of origin, as well as
a 35 percent local content value-added requirement, will be covered by the
agreement’s duty-free provisions that are scheduled for a 10-year
phase-in. Footwear articles must meet a
basic 35 percent local content origin rule. The agreement also preserves the
advantages enjoyed by Jordan’s Qualified Investment Zones (QIZs), which partner
with Israeli manufacturers under the U.S./Israeli FTA. AAFA supports
the FTA with Jordan to further the Middle East peace process.
·
Singapore and Chile: In November 2000, former President Bill
Clinton initiated negotiations for a bilateral free trade agreement with Singapore. In December, he followed suit by announcing
plans to negotiate a separate bilateral FTA with Chile. In compliance with notification procedures
under TPA, the Bush Administration has announced its intention to conclude both
agreements as soon as possible and is now engaged in a series of negotiations
with each party on issues as diverse as rules of origin, market access,
investment, intellectual property rights and services. AAFA is studying the issue of
negotiating FTAs with Singapore
and Chile,
especially in terms of the precedents that may be set for future agreements.
·
Vietnam: On December 10, 2001, US Trade Representative Robert Zoellick
published a Federal Register
notice implementing the July 13, 2000 U.S./Vietnam Bilateral Trade Agreement,
which provide Vietnamese imports access to Column 1 duties under the Harmonized Tariff
System. The agreement (P.L.
107-52) was approved easily in the House (on September 6, 2001 by voice
vote) and in the Senate (on October 3, 2001 by a vote of 88 to
12) and was signed into law on October 16, 2001. Congress still has an annual opportunity to consider Vietnam's
normal trade relations (NTR) status in a manner similar to previous annual
votes on China. For the past several
years, Congress has rejected similar efforts that would have curtailed U.S.
economic relations with Vietnam. The
most recent such vote occurred on July 23, 2002, when the House disapproved a
motion (H.J.
Res 101) by
a vote of 91 to 338 to curtail U.S./Vietnam economic relations. The Bush Administration has announced it
will negotiate an agreement to impose quantitative restraints on Vietnam’s
textile and apparel exports to the United States and conventional wisdom
suggests that such an agreement will take effect in early January 2003,
possibly with labor incentives similar to those negotiated with Cambodia. AAFA supports full
economic normalization with Vietnam and opposes the imposition of quotas on
Vietnam. AAFA recently took a
delegation of apparel and footwear executives to Vietnam to explore new
business opportunities.
·
Cambodia: The United States recently negotiated a new bilateral quota agreement
with Cambodia that provides an opportunity for quotas to increase up to an
additional 18 percent each year if working conditions in the garment industry
substantially comply with internationally recognized core labor standards. For the year beginning January 1, 2002, the
United States granted Cambodia a nine percent increase recognizing Cambodia’s
progress in achieving labor reforms.
Progress recorded in a recent International Labor Organization (ILO)
report may herald additional increases during 2002. AAFA believes that such accords should
provide opportunities for foreign garment industries to measure their
compliance using programs such as WRAP.
11.
Doha Round: The United States and the more than 140
other countries of the WTO agreed to launch a new
multilateral trade round in Doha, Qatar in early November 2001. In the final declaration,
trade ministers agreed to negotiations that could lead to reductions in
textile, apparel, and footwear duties.
Tariffs for these industries are extremely high in many countries,
creating so-called “tariff peaks” that stand in sharp contrast to the lower
duties faced by most products. In the
United States, for example, about 46 percent of all Customs duties are
collected on imports from just the four apparel, headwear and footwear
harmonized tariff chapters while those chapters only comprise about 7 percent
of all U.S. imports. In a companion agreement
on implementation issues, WTO members also agreed to review the growth
rates of quotas under the WTO Agreement on Textiles and Clothing (an exercise
that has failed miserably) and agreed that countries should “exercise
particular consideration before initiating” trade remedies upon expiration of
quotas. With trade ministers scheduled
to meet again in Mexico in September 2003, negotiators are now scrambling to
address market access and other issues before May 31, 2003. Demands by developing countries for “special
and differential treatment” may ultimately delay progress past the January 1,
2005 deadline when all negotiations are scheduled to be completed. AAFA supported the launch of a new round of
multilateral trade negotiations at Doha to address tariff and non-tariff
barriers in key markets.
Government Contracting Issues
12. Preservation of “Berry Amendment” Buy America protections. The Berry Amendment is a 60-year staple of Defense procurement law that requires the Defense Department to procure clothing and footwear, and their inputs, in the United States from U.S. manufacturers. This provision is important to maintain the warm industrial base in the United States for military needs, such as the current conflict being waged in Afghanistan. The industry has had to spend previous years fending off attempts by Sen. John McCain (R-AZ) and others to dilute the Berry Amendment. In 2001, because of the Defense Department’s ill-advised decision to source berets in China and other countries (thus waiving Berry), Congress instead focused on ways to strengthen elements of the Berry protection. Ultimately, Congress approved a provision (Section 832) in the FY 2002 Defense Authorization Act (P.L. 107-333) that more clearly codifies Berry into law. The Pentagon is now developing regulations in response to a solicitation of comments on this codification. AAFA supports preservation of the Berry Amendment as a vital way to maintain a warm industrial base for the national defense.
13.
Reform of Federal Prison Industries (FPI). The FY 2002
Defense authorization legislation also figured prominently in efforts to reform
Federal Prison Industries (FPI). Section 821 of S. 1438
contains a provision that requires FPI to meet the same price, quality, and
delivery time requirements met by the private sector. Previously, the Defense Department had to use FPI as the source
for its items if FPI wanted to claim the contract. Although Sen. Phil Gramm (R-TX) has successfully stripped similar
provisions from previous years' defense bills, he failed on September 25 when
the Senate tabled
an amendment to strike this provision by a vote of 74 to
24. Attention now turns to the
Administration, which is now in the process of developing regulations in
response to a solicitation of comments
on this new provision. Plans are also
underway for Congress to consider further reform. On April 25, the House Judiciary Committee approved legislation (HR 1577)
that has been sponsored by Rep. Pete Hoekstra (R-MI) and more than 100 of his
colleagues. If enacted – either as a
stand-alone bill or as part of a larger package such as the FY 2003 Defense
Authorization bill now pending in Conference – this provision would repeal
FPI’s mandatory source requirement over a 6-year period. Although there were strong hopes that this
provision could be added to the Defense Authorization bill, it now appears that
the authorization bill will not address any FPI issues that do not address
military contracting issues. AAFA
supported the enactment of the Section 821 as a key first step in efforts to
make FPI more accountable and subject to greater and more effective oversight
in order to level the playing field for U.S. contractors.
14.
State Contracting Rules. Since 9/11 there
has been an increase in the number of states imposing new “Buy America” or “Buy
Union” requirements for textiles and apparel.
In New Jersey, Governor McGreevey signed Executive Order Number 20 that
requires bidders to make a number of commitments about their labor practices,
including several that appear to stand in conflict with federal guarantees
protecting the right not to form unions.
Separately, a recent New York law establishes
a registry of apparel companies adversely affected by 9/11 to give those firms
a preference when they bid for state (and possibly other New York local)
apparel contracts. That law also
provides for responsible apparel procurement for the New York State and City
University system. Although
AAFA supports efforts to promote responsible apparel production at the state
level, AAFA is concerned that new contracting regulations could interfere with
existing rights of U.S. apparel companies to secure business at the state
level.
Labor Issues
15. Sweatshops/child labor: Various initiatives continue to attack the apparel and footwear industries for alleged use of sweatshops and child labor. In the past three years, there were a number of initiatives relating to Saipan (both legislation and legal cases to discourage apparel production in Saipan), child labor (new federal or state regulations and guidelines to prevent import or procurement of products made with forced or indentured child labor), and joint liability legislation at the federal and state level to make retailers and manufacturers financially liable for the labor practices of their contractors. The AAFA and a number of other apparel and business trade associations from around the world have endorsed the Worldwide Responsible Apparel Production (WRAP) Principles and have endorsed the development of a voluntary WRAP Certification Program. AAFA is educating policy-makers on the importance of this program and the role it is playing in stopping sweatshops and promoting apparel and footwear production under socially responsible and humane conditions. AAFA opposes sweatshops, which are morally offensive and represent unfair competition. AAFA endorses the WRAP as a way to establish a standard, cost-effective method of monitoring and certifying apparel and footwear factories worldwide. AAFA strongly opposes joint liability legislation at either the federal or state level. AAFA supports initiatives to eliminate forced and indentured child labor and endorsed the child labor treaty.
16. Minimum wage: Senate and House Democrats continue to push for a $1.50 increase in the minimum wage over a three-year period. Although this legislation appeared to have some momentum at various points during the last Congress, it ultimately stalled. Some believe that some form of a minimum wage bill could still be enacted this Congress, especially if Democratic leaders in the Senate insist upon such a provision as a quid pro quo for other legislation sought by Republican colleagues. AAFA supports legislation to keep the U.S. minimum wage at current levels.
17.
Ergonomics standards: Despite
strong opposition from Republicans in Congress and the business community, the Occupational Safety and Health Administration
(OSHA) issued its final
rule on ergonomics in November 2000. The final rule, which took effect in
mid-January 2001 during the closing moments of the Clinton Administration,
would have required employers to develop and implement wide-ranging programs to
prepare for and respond to potential ergonomics hazards. In March 2001, Congress rescinded these
rules upon passage of a special revocation procedure (S.J.Res 6). Several members of Congress, however, have
introduced legislation (S. 277/HR 655/S. 2184)
calling on OSHA to reissue new ergonomics rules. Others have inserted provisions in the FY 2003 appropriations
bill that would provide funding for the issuance of new ergonomics
standards. Following a national forum
on ergonomics, at which AAFA testified, OSHA has announced a series of voluntary guidelines on
ergonomics practices. AAFA
opposed the promulgation of a federal one-size-fits-all rule on ergonomics,
especially since apparel and footwear industries have recognized and promoted
good ergonomics practices for years.
18. Children's clothing: In 1996, the Consumer Product Safety Commission (CPSC) modified the children’s sleepwear flammability standards to permit the sale of children’s sleepwear made from non-flame resistant material for sizes 0-9 months or that meet certain snug-fitting dimensions. On June 28, 1999 – in response to a congressional mandate – the CPSC reaffirmed this rule with additional labeling requirements. Nevertheless, opponents of the rule have continued to push for its defeat or dilution through stand-alone legislation or amendments to the appropriations process. To date, none of these proposals has been enacted. So far in the 107th Congress, a series of bills (HR 730/HR 528/S. 2188/S. 2208) have been introduced in the House and Senate seeking a repeal of these amendments. However, none have seen any action. Separately, the CPSC has proposed a possible rule to require all items marketed for children (including clothing) to carry product registration cards. Finally, the New York State legislature has approved legislation that would create a rule on drawstrings that exceeds the ASTM standard that is widely observed by the industry. This action, which has not yet been endorsed by Governor Pataki, would replicate a similar action that was taken by the State of Wisconsin several years ago. AAFA strongly supports the retention of the 1996 children's sleepwear amendments but strongly opposes any rule to require product registration cards or legislate a new drawstring standard.
19.
Flammable Fabrics Review. On September 12, 2002, the Consumer Product
Safety Commission issued a notice of Advanced
Proposed Rulemaking (ANPR) to review and update the testing standards for
the general wearing apparel flammability standard. Comments are due on November 12, 2002. AAFA intends to review and comment on this ANPR.
20.
Labeling Issues:
The Federal Trade Commission (FTC) and
the U.S. Trade Representative are working with the Canadian and Mexican
governments on a draft agreement that would harmonize the meaning of care label
symbols across the three NAFTA countries. A separate initiative may be
undertaken to permit the FTC and the Canadian government to recognize each
other’s manufacturers’ ID numbers. This
initiative requires legislation since the FTC is only statutorily permitted to
recognize its own ID scheme.
Separately, the FTC is examining the impact a notice it recently
published that would seem to change current practice and require goods assembled
abroad from U.S. fabric to disclose both the country of assembly and the origin
of the U.S. inputs. AAFA is working with the FTC to promote harmonization and
simplification of labeling rules.
Other
21.
Funding for NTC/[TC]2:
Each year, the National Textile
Center (NTC) and the Textile/Clothing
Technology Corp. [TC]2 receive federal appropriations through the annual
Commerce/Justice/State appropriations bill to support their work to advance the
competitiveness of the U.S. textile and apparel industry complex. Over the years, NTC has received between $7
million and $9 million while [TC]2
usually receives around $3.5 million.
FY 2002 funding levels set in the conference
report for PL 107-77 are $10 million and $3 million, respectively, while FY 2003
levels appear to be on target for similar amounts. AAFA supports continued funding for NTC and
[TC}2.
For additional information, please contact the AAFA Government Relations Staff at 800.520.2262 or through the “Legislative/Trade Action Center” section of the AAFA Web Site at www.apparelandfootwear.org. You can also get more information by clicking on the hot links embedded throughout this document.
Updated: September 13, 2002