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SCOPE OF WORK The purpose
of this report is to analyze the post-Multi-Fiber Arrangement
(MFA) environment for the textile and apparel sectors in light
of the recently extended African Growth and Opportunity Act
(AGOA) in reference to Common Market of Eastern and Southern
Africa (COMESA) members with particular emphasis on Ethiopia,
Kenya, Madagascar, Mauritius and Uganda.
This study reviews the ramifications for current and potential
textile and apparel producers within these countries. The
paper will suggest steps for the survival and growth of the
COMESA textile and apparel industry.
This project will be conducted in two phases. Phase One provides
a comprehensive report on the textile and apparel industry
in these five countries. Phase Two will focus on the dissemination
of the report through; inter alia, workshops with key stakeholders.
Phase Two will be designed and finalized immediately after
the completion of Phase One.
This analysis takes place in the context of the most climatic
event affecting trade in textiles and apparel over the past
fifty years – the termination of textile and apparel
quotas on January 1, 2005. The paper analyzes five issues:
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Global impact of the new trade regimes to replace the
Agreement on Textiles and Clothing (ATC);
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Current AGOA provisions and countries performance under
these provisions;
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Impact on the five countries’ competitiveness in
the post-MFA world. The study will look specifically on
the impact of MFA termination on prospects for textile
and apparel investment under the African Growth and Opportunity
Act (AGOA).
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Comparison of export prices and costs of production in
the COMESA countries compared to other countries. This
aspect of the study focuses on such determinants of competitiveness
as –
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Level of efficiency and productivity of labor and
machines;
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Satisfaction of quality standards;
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Labor standards and compliance with international
standards;
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Competence of management and level of awareness of
international competition;
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Existing laws and facilities to boost export
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Suggested measures to be taken by the COMESA Secretariat,
national governments, the U.S. Government and other donor
entities to attract and expand investment in the textile
and apparel sectors. Special focus is paid to steps countries
can take to improve their enabling environment.
The time between completion of the draft and actual publication
and distribution has seen publications of a number of additional
studies and a number of devilments in the post MFAworld. We
thus have included an update section at the beginning of the
study.
February 22, 2004: UPDATE OF STUDY
OF TEXTILE AND APPAREL INDUSTRY IN SELECT COMESA COUNTRIES
IN POST- MFA ERA
In the ensuing six weeks since the submission of the “Study
on the Impact of the End of MFA Quotas on AGOA Textile Exports
from Select COMESA Countries,” uncertainty among COMESA
AGOA apparel manufacturers intensified in light of unanswered
questions about the post-MFA situation. The sections on textiles
and apparel in the International Trade Commission’s
(ITC) “Fifth Annual Report on U.S. Trade and with Sub-Saharan
Africa (SSA)” issued on January 13, 2005 confirmed a
number of the conclusions in the impact study, but also provided
new insights on the impact of the elimination of quotas. Finally,
the press has contained many insightful articles on the post-MFA
world.
We have prepared this addendum to review these factors to
assure that the “Impact Study” does not lose its
timeliness since the drafting of the paper.
Summary
It will be many months before one will be able to make any
definitive determination on the impact of the end of the MFA
on the COMESA countries visited in the study. Many buyers
are simply waiting to see what the post-MFA trade regimes
will be before significantly changing current buying patterns.
The future of SSA exports vs. a vs. China will be determined
in major part by the extent to which Chinese exports are subject
to safeguards in the United States. Decisions on whether to
impose such safeguards are still one to three months away2.
China is imposing an export tax but, unfortunately, it is
applies at such a low level (about 2 to 4 US cents per unit)
as to be ineffective in limiting exports from China to the
United States.
Other uncertainties revolve around whether and if so, the
level of any revaluation of the Chinese currency, price movements
in other suppliers, particularly in Bangladesh, CBI countries,
Mexico, India, Indonesia, Pakistan and Thailand, the availability
of competitively priced yarns and fabrics to SSA clothing
manufacturers and if and when the quantity of Sub-Saharan
African apparel incorporating third country yarns and fabrics
eligible for duty-free treatment is halved in 2006 and zeroed
out in 2007. We also expect many suppliers to try to move
up to higher priced products leaving room for Sub-Saharan
African exports at the lower end of the price scale. Steps
taken to improve the efficiency of production in SSA will
also influence the final impact of the elimination of quotas.
These continuing uncertainties make predictions of gloom and
doom premature.
A concrete positive sign is that at least through the end
of 2004, the COMESA countries visited have been able to maintain
market share and in fact increase market share vis-à-vis
the largest AGOA exporter -- Lesotho. Even Mauritius has been
successful in moderating a decline in exports to the United
States by introducing measures increasing that the share of
its exports that can enter under duty-free provisions of AGOA.
US retailers and other importers have adopted a wait and
see attitude and have not significantly changed their sourcing
patterns—a situation is expected to continue through
at least June.
However, there have been negative reports in late 2004 and
in early 2005 about plant closures and job layoffs. In Kenya,
there were reports that 5 plants employing 8,000 workers had
laid off workers. In addition, the recently released 2005
ITC study on Trade and Investment in Africa, predicts that
Madagascar and Kenya will be among the countries losing market
share in the post-MFA world. The 2005 ITC report highlights
structural challenges facing AGOA suppliers.
The report does document that with the exception of Indonesia,
labor costs are lower in the apparel sector of Madagascar
and Kenya than in any other apparel exporter to the United
States. However, this advantage is offset by low productivity
in SSA. This appears to reinforce the paper’s conclusion
that there is no more important step that COMESA countries
can take than to improve the productivity of sewing machine
operators, improve middle management and introduce system
engineers to improve the operation of textile plants. In recent
studies, one has identified the high costs of inland transportation.
An additional measure being considered in some of the countries
visited is governmental subsidization to defray high costs
for power and other infrastructure externalities. Also, there
is consideration of special facilities for working capital
and short-term financing.
Various trade initiatives benefiting non-AGOA beneficiaries
could further undermine AGOA benefits. Duty-free privileges
for apparel incorporating third country fabrics were extended
to Egypt (a COMESA member but non-AGOA beneficiary). Egypt
can now ship unlimited amounts of such garments from three
specified areas (Qualified Investment Zones (QIZs)) provided
the apparel incorporates required but minimal amounts of Israeli
and Egyptian content.
The termination of such duty-free treatment for apparel containing
third country fabric might have to be reevaluated. However
any extension of the third-country fabric/yarn provision must
be done so in the context of investment promotion or other
forms of incentives for the production of Sub-Saharan African
yarns and fabrics to be incorporated in African apparel exports
to the United States.
The Major Emotion Prevailing in the Apparel Industry in the
Countries Visited Is Uncertainty.
The uncertainty is caused by a number of factors. The most
pressing is continuing delays in the decision on whether to
impose safeguards on China, and if applied, at what level
and on which products. It will be at least 30-90 days before
a decision is made.
The US industry had initially filed in November and December
petitions to the Department of Commerce requesting that the
United States Government implement at the beginning of 2005
safeguards in a number of categories due to the threat of
potentially disruptive surges from China in the post-MFA world.
The categories in the petitions included woven trousers and
knit shirts—the major exports from COMESA suppliers.
An injunction issued by the US Court of International Trade
barred the Department of Commerce (Committee for Implementation
of Textile Agreements--CITA) from promulgating safeguards
on Chinese imports based on allegations of “threat”
as opposed to actual disruption. Importers had argued that
US legislation based on WTO commitments require CITA to find
actual disruption, not only threat. It will take at least
until April for any action to be taken against China. It will
take at least that long to collect data on actual imports
and for CITA to consider whether the data justifies imposition
of quantitative restrictions on China.
The impact study mentioned the possibility that China might
limit its own exports of low priced apparel thereby providing
a breathing space for AGOA. It is now confirmed that China
is implementing a special export tax on six different categories
of products including products that also are produced in COMESA
LDC suppliers -- woven trousers and knit shirts. The export
tax is a flat fee that should discourage low price exports
from China that are in price ranges currently being shipped
from the LDCs. However, it is being applied currently at such
a low level ($0.2 to $0.4 per piece) as to have no impact
on trade and is considered to be ineffective window dressing
by Sub-Saharan African producers and their customers.
There also was speculation that China might implement a minimum
export price below which products cannot be shipped in a number
of categories including those exported from the visited COMESA
companies. This would serve as an inducement for Chinese exporters
to move into higher niche exports leaving more basic apparel
open to African exporters. However, no action has yet been
taken on this proposal as of the now.
Other uncertainties revolve around unresolved efforts to
revalue the Chinese Renminbi, uncertain price movements in
Asian and other competitive suppliers and the absence of alternative
competitively priced yarns and fabrics to replace third country
yarns and fabrics when AGOA third country provisions are halved
in two years and completely removed the following year. There
is concern that Asian producers currently operating in select
COMESA countries will transfer production back to Asia.
Mixed Developments in AGOA Apparel Exports in Countries
Visited
Although mixed, initial soundings are not good. Kenya has
reported five factories closings with a layoff of 8,000 workers.
The East African Standard has been full of gloom and doom
articles bemoaning the competitive threat facing Kenyan exports.
The paper estimated that 25,000 employees working in 37 textile-manufacturing
firms might lose their jobs during the first post MFA year.
This follows reports of more serious plant closings and layoffs
in Southern Africa, specifically Swaziland and Lesotho.
However, there are some positive indications as well. Investors
in Madagascar are predicting 10 percent growth in 2004. A
number of Kenyan producers have visited with Hub personnel
and indicated that business was going on as usual.
The factories that closed in Kenya were not state of the art.
They lacked marketing facilities of more sophisticated operations.
These factories did not rely on direct orders, but on overflow
orders from other companies for cutting and manufacturing.
These firms also suffered from high production costs and insufficient
working capital.
Visited COMESA LDCs Continued to Do Well through
the End of 2004
The most recent statistics for the visited COMESA countries
do not show any drop-off in exports. The last three months
of 2004 corresponding to the first three month of AGOA year
2005 was not gloom and doom as predicted by elements in the
East African press. For the five countries visited in the
study, there were different degrees of good news. The four
LDCs visited Kenya, Madagascar, Uganda and Ethiopia -- all
continued to grow their exports over the previous year. Even
though Mauritius, the only non-LDC visited, continued to experience
overall export declines, there was positive growth in categories
eligible for AGOA duty-free treatment.
During this last quarter of 2004, Madagascar and Kenya exported
19.2 million and 18.9 million SME respectively. A simple projection
of the three-month total to a full year shows that both countries
would export about 76 million SME each for the fifth AGOA
year ending September 30, 2005 if they continued at the current
pace. During the previous year, exports in these categories
amounted to 61 million and 62 million SME. This would translate
into growth of 25 percent for each country if growth continued
at the same pace until the end of AGOA Year 5 on September
30, 2005. As recently as early February, investors in Madagascar
were still expecting growth of more than ten percent.
Uganda and Ethiopia, starting from a much lower base, also
continued to grow in the apparel sector. During the three-month
period between October-December, 2004, Uganda exported 389,000
SME, which is at a rate of 1.6 million SME for the year. This
would compare to 1.3 million for all of AGOA Year 4 or a growth
of about 233 percent. Ethiopia also appeared in statistics
with exports of apparel amounting to 516,000 SME, which can
be projected to about 2.1 million SME for the year. This would
compare to 1.7 million SME in AGOA Year 4 or a projected growth
of 24 percent. We would remind you however, that Ethiopia
is focusing on textile mill production.
The two largest LDC exporters visited, Madagascar and Kenya,
remained virtually tied for second place among AGOA supplier.
However, they reduced the lead of front-runner Lesotho. In
AGOA year 4, Lesotho accounted for 34 percent compared to
20 and 19 percent for Kenya and Madagascar respectively. For
the first three months of AGOA year 5, Madagascar and Kenya
were tied for second with about 21 percent each compared to
Lesotho’s 29 percent share
The lagging market share of Lesotho can be traced to a number
of factors of which the most important is the appreciation
of the rand--the Lesotho currency (the maloti) is pegged to
it. The ITC report contained industry speculation that if
the South African rand continues to strengthen against the
dollar, many investors will pull out of Lesotho.
In addition, industry sources at a Chinese owned mill in
Lesotho claimed that their salary costs, even exclusive of
productivity differences, are almost three times greater than
what they would be at comparable facilities in China. Six
company owners who closed shop last year clearly believed
that the low wages, economies of scale and efficient engineering
of factories in China and India would eventually crowd them
out of the market.
Mauritius May Have Found a Production Niche A
lthough total exports from Mauritius declined in 2004 compared
to 2003 by 16 percent, there is a silver lining within these
figures.
Mauritius is not an LDC AGOA beneficiary of the program.
In order to qualify for duty-free treatment, non-LDC beneficiaries
must comply with the rules of origin that require that the
apparel incorporate yarn spun and/or fabrics formed (knitted
or woven) in the United States and/or in an AGOA beneficiary
unless they are shipping under special provisions. LDCs beneficiaries
receive a blanket exception allowing duty-free entry for apparel
assembled in their countries from third country yarns and
fabrics.
Mauritius has adhered to three strategies to increase its
duty-free exports to the United States. The original impact
study would refer to such strategies as being “AGOA
smart.”
Mauritius took advantage of a provision in AGOA that exempts
from the origin rule, apparel incorporating yarns and fabrics
found by the Department of Commerce to be in short supply
in the United States. A Mauritius petition was accepted that
argued that certain high quality fabrics used in men and boys
shirts (containing average yarn count exceeding 135) was in
short supply. The result has been that Mauritian companies
have been able to ship duty free woven shirts incorporating
fabric that does not meet the origin rule. In fact, Mauritius
is shipping shirts produced from Chinese yarns woven in China
and from such yarn spun in Italy but woven in Mauritius. This
short supply provision is available to all AGOA beneficiaries
including COMESA members. In 2004, about 22 percent of total
Mauritian imports into the United States are estimated to
have entered the United States under this provision.
Mauritius also has been able to ship apparel made from locally
spun yarns particularly knit polo shirts. Duty-free entry
for apparel produced from regional yarns and fabrics is projected
to have increased from 13 million SME in AGOA Year 4 to about
15 million SME in AGOA Year 5. About 35 percent of total Mauritian
exports to the United States are estimated to have entered
the United States duty-free under this provision.
The study observed that Mauritius had lost its only factory
spinning yarns for weaving bottomweight fabrics that are incorporated
in the manufacture of trousers. Such trousers would no longer
meet the origin requirement for AGOA duty-free treatment specifically
that fabric is woven from yarns spun in an AGOA beneficiary
country. An enterprising foreign investor has now agreed to
take over the mill and produce on the island. Once this factory
is in operation and its output is incorporated into Mauritian
exports, the share of duty-free exports from the Island will
increase even more.
Third, Mauritius successfully lobbied to modify AGOA’s
LDC provisions. The waning days of the last Congress saw enactment
of a bill allowing Mauritius to ship up to five percent of
the special TRQ reserved for LDCs shipments of apparel incorporating
third country yarns and fabrics. The bill is in effect only
for AGOA Year 5 and in practice would allow Mauritius to ship
up to 27 million SME of apparel that would otherwise pay full
duty. The bill may well be extended for additional years.
Statistics on Mauritian exports to the United States demonstrates
the success of this AGOA smart strategy. The shares of duty-free
imports in total apparel imports from Mauritius increased
from 44 percent to 59 percent during the first eleven months
of 2004. When the eleven months of 2004 are projected for
the whole year, dutiable imports will have declined by 43
percent in 2004, duty-free imports will have increased by
17 percent.
ITC Not Sanguine About Future of AGOA Apparel Production
The ITC emphasized that of all the regions analyzed in the
post-MFA world -- China, other countries in East Asia, South
Asia, ASEAN, Mexico, Caribbean Basin, Andean and Middle East,
SSA faces the greatest challenge to remain a viable supplier.
The ITC concludes that before the MFA expired, US retailers
were increasing their purchases under AGOA since they did
not have to pay duties on their imports. However, without
quotas on non-SSA suppliers, the absence of duties likely
would not retain Sub Sahara’s competitive advantage
except in cases where import duties are high (man-made fiber.)
In addition to being a high cost producer, the key competitive
factors that harm AGOA in comparison with other textile exporters
are that AGOA suppliers generally
- produce basic rather than fashion garments,
- do not offer full package services,
- have limited capacity to offer large volumes, and
- possess inferior logistic and infrastructure compared
to other sources.
Other cited factors are the lack of integrated production
from cotton-yarn-fabrics-apparel, AGOA LDCs being relatively
new suppliers, not being located in proximity to the United
States and not having the required managerial and sewing skills
to move up to niche production (except of course for Mauritius.)
The ITC report expands on the significance of full package
production. Buyers prefer to source from full package providers.
Manufacturers in East Asia are best able to carry out the
four stages required for full-package production. Full package
includes product development, fabric sourcing, cutting, garment
sewing, packaging, quality controls, trade, financing, and
logistic arrangements. AGOA LDCs usually just cut and sewed
garments.
An advantage that accrues to the Caribbean Basin and Mexico
from being close to the United States is point of sale replenishment.
Manufacturers can ship store-ready products to retailers on
the basis of retail point-of-sale data
For Mauritius, the ITC report points out that the challenge
facing Mauritius are counteracting high labor costs due to
labor shortages and competition from high-tech sectors. However,
it does not address the potential of the country’s efforts
to enter niche production within categories eligible for AGOA
duty-free entry.
Both the ITC report and the impact study emphasize SSA’s
wage rate advantages. The 2002 statistics cited in the ITC
report show that average hourly wage in apparel industry are
$0.33 and $0.38 cents in Madagascar and Kenya respectively.
The only countries where hourly wage rates were close to these
levels were Indonesia ($0.27), India ($0.38), Bangladesh ($0.39)
Pakistan ($0.41) and Sri Lanka ($0.49). Other apparel producers
with higher hourly wages but still less than $1.00 per hour
are Egypt ($0.77), China ($0.88), Philippines ($0.91, Nicaragua
($0.91) and Colombia ($0.98).4
Mill Production Continues to Lag Apparel Production
The ITC report indicates that most firms in SSA view vertical
integration as an important survival factor in the post-MFA
world. They noted that the region’s apparel industry
is undermined by the limited availability and high cost of
regional inputs, compared with countries such as China and
India. Regional textile mill production will be particularly
important to SSA apparel makers starting in October, 2006
when the tariff rate quota allowing imports of third country
fabric will be halved to levels below current exports. By
October, 2007 it will be eliminated unless AGOA legislation
is modified.
Unfortunately, the ITC report offers no additional reasons
to those cited in the impact study to be sanguine about the
possibility of regional yarns and fabrics substituting for
current usage of third country fabrics. The report observes
that although SSA has an important textile fiber base, SSA
LDCs lack the manufacturing investment required to use these
fibers. The major problem in developing such facilities is
the high cost of establishing textile mills in SSA. A standard
textile mill with yarn spinning, fabric weaving or knitting
and finishing facilities costs about $25 million not including
infrastructure investment compared to about $2.5 million for
apparel manufacturing. Infrastructure deficiencies add to
the cost of production as well. The ITC report cites a company
estimates that the cost of standard cotton chino imported
from China into Lesotho was $0.58 per square yard compared
to $1.57 for identical fabric produced in South Africa.
The ITC report argues that only a small variety of fabrics
can be produced in SSA. This is a disadvantage for the region
as buyers and fashion dictate the types of fabrics used especially
as producers move up-market. The failure of textile to diversify
or move up market has serious implications. Once the third
country provisions expire, AGOA exporters must incorporate
into garments only a narrow range of yarns and fabrics to
benefit from duty-free entry.
With the exception of Ethiopian efforts to refurbish its mills
and so-called captive investment in Mauritius and Madagascar,
there is little activity to develop fabric production in the
region. Mauritius is producing knitted fabric, but in insufficient
quantities to substitute for third country fabrics currently
being used in Mauritian apparel factories.
The ITC report stated that Kenya’s cotton supply fell
short of demand and is high priced. Malawi expressed concern
that if the AGOA third country fabric provision was not extended
for another three years, continued production would be difficult.
The report also stated that the leading apparel producer,
Tri-Star, in Uganda is sourcing fabrics from Sri Lanka because
of concerns about the quality of locally produced components.
The company announced last April that it planned to produce
domestically. but there is no indication that there will be
a switch away from third country components in the near future.
The negative projection on textile mill production in the
Impact Study appears still to be accurate.
The impact study emphasized the importance to manufacturers
in the visited countries of efforts of Ethiopia to upgrade
and expand cotton fabric production. Ethiopia is well-positioned
to supply its own apparel industry and neighboring producers
with high quality cotton yarns and fabrics.
The development of competitive textile mills require more
than simply ending preferences for AGOA apparel incorporating
third country materials. Withdrawal of duty-free treatment
before SSA textile mill production is available would harm
the mills since apparel factories would cease production and
there would be no demand SSA produced yarns and fabrics. Textile
mills will only grow and prosper, if SSA apparel manufacturing
remains viable.
Another requirement for building such mills is development
assistance focusing on the improvement of the cotton/textile
sector from growing, to ginning and cleaning, to spinning
to weaving. This involves not only incentivizing improvements
in cotton production and establishing world class textile
mills but also needs investment in infrastructure particularly
power and transportation. There must also be an enabling environment
to encourage private sector investment—government-owned
plants do not work. Unfortunately, time is growing short.
If provisions allowing AGOA apparel incorporating third country
fabrics are extended, they must be extended in a way that
provides some incentive to replace third country with regional
fabrics and yarns. The extension could accomplish this by
including a bonus whereby manufacturers using regional fabrics
receive a special allocation for apparel incorporating third
country fabrics. Duty-free treatment could be expanded to
include access for third country fabrics and made-up goods—a
difficult proposition given the political strength of the
US textile industry.
Suggestions for Assuring Continued Viability of the
Industry
The highest priority is for SSA LDCs to improve productivity
through increasing output per manhour. The ITC confirmed the
ECA Hub’s emphasis on improving skill levels in the
textile and apparel industry. It highlights the importance
of upgrading the of sewing machine operators given the increased
competition in the post MFA world. It reinforced the need
for system engineers by citing various cases where apparel
operations were poorly organized. Finally, it mentioned the
importance of improved managerial skills specifically middle
management.
AGOA suppliers are increasingly resorting to investor friendly
measures to promote production. After resisting for a number
of years, Madagascar is now remitting value-added taxes to
producers, allowing foreigners to purchase land and eliminating
import duties on fabrics. Kenyan producers are requesting
subsidies to offset high priced power. Direct export subsidies
such as those available in Nigeria, are being considered to
promote garment manufacturing.
One of the experts contracted for this work believed that
there are steps that the United States could take to end this
uncertainty and restore confidence in AGOA production.
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Implement strict safeguards against Chinese exports
in the products produced in Africa—low cost pants
and knit shirts.
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Continue efforts to have the Chinese Renminbi revalued
by at least 40 percent.
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Guarantee for the period of AGOA validity, duty-free
access for apparel incorporating third country fabrics
so as to allow African producers to maximize their competitiveness
by procuring yarns and fabrics from the most efficient
sources.
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Encourage textile mill production by allowing shipments
of textile mill products specifically yarns, fabrics and
made-up goods.
-
Provide technical assistance to assist AGOA producers
to upgrade their human skills particularly through upgrading
sewing and machine maintenance, enhance managerial performance
and improve system engineering.
Trade Legislation in Washington
A challenge to maintaining AGOA’s preferential margins
is the continuing spread to other countries of preferential
entry into the United States for apparel.
Under a tripartite agreement between Egypt, Israel and the
United States, three trade zones were designated as eligible
for QIZ benefits, This means that if they contain minimum
quantities of Egyptian, Israeli and American inputs, they
could ship duty-free to the United States. There is no limit
on the amount and no termination date for the program. It
is estimated that more than 85 percent of Egyptian apparel
exports to the United States will originate in these zones.
Congress is considering legislation—Tariff Relief Assistance
for Developing Economies (TRADE) that will provide preferential
duty entry to 14non-African LDCs plus Sri Lanka. The bill
is modeled after AGOA in that it provides duty-free treatment
for apparel produced from third country yarns and/or fabrics.
The amount of duty-free treatment is limited to eleven percent
of total US imports which is equivalent to the countries’
current level of imports. The bill allows for growth to 14
percent over a ten year period. A separate bill will be considered
for Haiti.
However, until the legislative procedures for both these
bills are concluded, we will not know whether any of these
bills will pass, and the extent of their preferential coverage.
To the extent that the final versions of the legislation allow
duty-free treatment for imports incorporating third country
fabrics, the competitive advantage currently enjoyed by AGOA
LDCs will suffer.
The initial impact study commented on the impact on AGOA
of free trade agreements awaiting Congressional approval or
being negotiated. FTA agreements with Bahrain and the Dominican
Republic/Central America are awaiting approval. Although a
number of FTAs are currently being negotiated only the agreement
with Panama, Colombia, Ecuador and Peru and with Oman and
the United Arab Emirate are likely to conclude this year.
These agreements will have little impact on AGOA unless they
provide access for apparel incorporating third country fabrics. |
