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Tariffs Trending: How Shifting Trade Policies Could Reshape the Fashion Industry

  • Writer: Alexa Lia
    Alexa Lia
  • Mar 14
  • 5 min read

Updated: May 8



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In a matter of weeks, the new administration has introduced significant trade policy changes, including increased import tariffs—specifically on China, Canada, and Mexico—and an effort to eliminate the de minimis exemption for imports.[1] These changes could reshape the fashion industry, forcing companies to reassess supply chains and sourcing strategies.[2]

 

Increased Tariffs

On February 1, 2025, President Trump signed executive orders raising import tariffs on China by 10% and Canada and Mexico by 25%.[3] As of March 4, the tariffs on all three countries have gone into effect, along with an additional 10% increase for China.[4] President Trump cited the International Emergency Economic Powers Act (IEEPA) as his authority, justifying these increases as measures to combat drug trafficking and illegal immigration.[5] However, the tariff increases may have unintended consequences for the fashion industry.[6]

 

The fashion industry relies heavily on imports, as only 3% of clothing is produced domestically.[7] China, responsible for over 20% of U.S. clothing imports, also supplies essential materials like textile dyes, which are not typically produced domestically due to environmental concerns.[8] Although posing challenges for companies dependent on these foreign imports, the tariffs could boost domestic manufacturer revenue by an estimated $700 million.[9] Additionally, reshoring could help manufacturers better manage lead times and product quality, avoiding the unpredictability of foreign manufacturers and international trade more broadly.[10]

 

Despite these potential benefits, domestic manufacturing may not increase as significantly as expected, as manufacturing abroad may still be cheaper even considering the tariff increases, and domestic labor shortages further complicate efforts to increase production.[11] Advancing technology could, however, help to abate these concerns as manufacturing processes become more automated.[12] Ultimately, the costs of supply chain disruptions and labor shortages will likely be passed along to consumers in the form of increased prices.[13]

 

De Minimis Exemption

Coinciding with the tariff orders, President Trump signed another order on February 1 to eliminate the de minimis exemption, which allows imports under $800 to enter the U.S. tariff-free.[14] Over 90% of all packages imported to the U.S. qualify for this exemption, with 60% originating from China.[15] The policy change primarily aims to curb opioid trafficking but has significant implications for fast fashion companies like Shein and Temu, which rely on the exemption to import large quantities of cheap clothing while keeping costs low for consumers.[16]

 

Without this exemption, fast fashion consumers may face higher prices and shipping delays, which could push consumers to shift to more sustainable brands.[17] This could be a welcomed shift due to growing concerns over forced labor and other ethical issues tied to fast fashion.[18] However, after significant disruptions in the shipping industry following the initial enforcement of the order, the administration temporarily reinstated the exemption, though the Commerce Department is working on procedures to implement the order effectively.[19]

 

Next Steps for the Fashion Industry

In response to these trade policy changes, fashion companies are exploring several strategies to mitigate costs and disruptions, including the following measures:[20]


  • Supply Chain Diversification: Shifting production out of affected countries, using manufacturers in Cambodia, Vietnam, or Free Trade Agreement (FTA) countries to minimize tariff exposure.[21]

  • First Sale Doctrine: Using the—often lesser—value of a good’s first sale (e.g., manufacturer to vendor) rather than the final sale (vendor to importer) for import valuation.[22]

  • Tariff Engineering: Modifying products by incorporating components from lower-tariff countries or completing assembly in the U.S. (or elsewhere) to qualify for reduced tariff rates.[23]

  • Domestic Manufacturing: Reshoring production to reduce reliance on foreign suppliers.[24]

 

Ultimately, while these strategies may help ease the impact of new trade policies, the fashion industry will likely still face significant costs, supply chain adjustments, and market shifts as companies and consumers adapt to the changing landscape.[25]


[1] Fact Sheet: President Donald J. Trump Imposes Tariffs On Imports From Canada, Mexico And China, The White House (Feb. 1, 2025) [hereinafter Fact Sheet], https://www.whitehouse.gov/fact-sheets/2025/02/fact-sheet-president-donald-j-trump-imposes-tariffs-on-imports-from-canada-mexico-and-china/; Laura Gottesdiener & Stephen Eisenhammer, Trump Closed a Loophole for Low-Cost Imports – Until All Hell Broke Loose, Reuters (Feb. 14, 2025, 10:44 AM), https://www.reuters.com/world/us/trump-closed-de-minimis-import-loophole-until-all-hell-broke-loose-2025-02-14/.


[2] See Jiana Smith, Trump Tariffs Signal Complicated Future for Domestic Apparel Industry, Times Square Inv. J. (Dec. 20, 2024), https://coveringcompanies.journalism.cuny.edu/2024/12/20/trump-tariffs-signal-complicated-future-for-domestic-apparel-industry/.


[3] See Fact Sheet, supra note 1.


[4] See Talya Minsberg, A Timeline of Trump’s On-Again, Off-Again Tariffs, N.Y. Times (Mar. 13, 2025), https://www.nytimes.com/2025/03/13/business/economy/trump-tariff-timeline.html (noting the initial 10% tariff increase on China took effect on February 4, followed by a second 10% increase on March 4, bringing the total tariff increase to 20%); see also Fact Sheet: President Donald J. Trump Adjusts Tariffs on Canada and Mexico to Minimize Disruption to the Automotive Industry, The White House (Mar. 6, 2025), https://www.whitehouse.gov/fact-sheets/2025/03/fact-sheet-president-donald-j-trump-adjusts-tariffs-on-canada-and-mexico-to-minimize-disruption-to-the-automotive-industry/ (stating the 25% tariff on Canada and Mexico does not apply to goods that fall within the United States–Mexico–Canada Agreement (USCMA)).


[5] See Fact Sheet, supra note 1.


[6] See Smith, supra note 2.


[7] Id.


[8] Id.


[9] Id.


[10] Shruti Ghosh, Challenges and Opportunities in the USA Garment Production, Maker’s Row (Sept. 25, 2024), https://makersrow.com/blog/challenges-in-the-usa-garment-production/.


[11] See Smith, supra note 2.


[12] See Ghosh, supra note 10 (referring to technology such as 3D printers and AI-powered design tools).


[13] Smith, supra note 2.


[14] Imposing Duties To Address The Synthetic Opioid Supply Chain In The People’s Republic Of China, The White House (Feb. 1, 2025) [hereinafter Imposing Duties], https://www.whitehouse.gov/presidential-actions/2025/02/imposing-duties-to-address-the-synthetic-opioid-supply-chain-in-the-peoples-republic-of-china/ (identifying the IEEPA as one source of authority to issue the order); Gottesdiener & Eisenhammer, supra note 1.


[15] Gottesdiener & Eisenhammer, supra note 1.


[16] See Imposing Duties, supra note 14; see also Megan Cerullo, Fast Fashion from Shein, Temu Could Get More Expensive and Take Longer to Ship. Here's Why., CBS News (Feb. 5, 2025, 6:07 PM), https://www.cbsnews.com/news/china-tariff-shein-temu-de-minimis-exemption/#.


[17] Cerullo, supra note 16; see Rebecca Ann Hughes, Trump’s New Tariff Will Hit Fast Fashion, but It’s Not Necessarily a Win for the Environment, Euro News (Feb. 8, 2025, 10:05 AM), https://www.euronews.com/green/2025/02/08/trumps-new-tariff-will-hit-fast-fashion-but-its-not-necessarily-a-win-for-the-environment.


[18] See Hope O’Dell, How Shein and Temu Get Around Us Labor Laws That Ban Products Made with Forced Labor, Bluemarble (Feb. 21, 2025), https://globalaffairs.org/bluemarble/how-shein-and-temu-get-around-us-labor-laws-ban-products-made-forced-labor.


[19] See Gottesdiener & Eisenhammer, supra note 1 (detailing that over one million packages piled up at U.S. customs for inspection); see also Amendment To Duties Addressing The Synthetic Opioid Supply Chain In The People’s Republic Of China, The White House (Feb. 5, 2025), https://www.whitehouse.gov/presidential-actions/2025/02/amendment-to-duties-addressing-the-synthetic-opioid-supply-chain-in-the-peoples-republic-of-china/.


[20] See Angela M. Santos et al., Here We Go Again… Trump Tariffs 2.0: What the Fashion, Beauty, and Retail Industries Should Know, ArentFox Schiff (Dec. 5, 2024), https://www.afslaw.com/perspectives/fashion-counsel/here-we-go-again-trump-tariffs-20-what-the-fashion-beauty-and-retail; see also Smith, supra note 2; Jeffrey G. Richardson et al., Preparing for Tariff Increases – Mitigation Strategies, The Nat’l L. Rev. (Dec. 13, 2024), https://natlawreview.com/article/preparing-tariff-increases-mitigation-strategies.


[21] Santos et al., supra note 20; Smith, supra note 2 (noting that relocating production is not the fastest solution, as it can take nearly two years to approve a new factory).


[22] Richardson et al., supra note 20.


[23] Id.


[24] Id.


[25] See Smith, supra note 2.

 
 
 
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