COLUMBIA SPORTSWEAR
Mr. R. Matthew Priest, Chairman
December 21, 2007
Mr. R. Matthew Priest, Chairman
Committee for the Implementation of Textile Agreements
U.S. Department of Commerce
Room H3001A
14th Street & Constitution Avenue, N.W. PUBLIC VERSION
Washington, D.C. 20230
Re: Petition Regarding the Commercial Availability of Certain Composite
Laminated Fabric
Dear Mr. Chairman:
Columbia Sportswear Co. herewith submits this request for a finding of no commercial availability pursuant to the provisions of Section 203(o)(4) of the Dominican Republic-Central America-United States Free Trade Agreement (“DR-CAFTA”) Implementation Act and your Federal Register notice of March 15, 2007, with respect to a certain composite fabric which Columbia wishes to use in the manufacture of apparel in a DR-CAFTA member country. By means of this letter, we request that the subject fabric be added to Annex 3.25 of the Agreement.
The fabric in question is a composite fabric consisting of a woven face fabric and knit backing fabric laminated together by means of a chemical adhesive and classified under HTS subheading 6001.22. Further details are shown in the accompanying Exhibit.
DUE DILIGENCE
The following firms and associations were contacted and asked if they or their members could supply the subject fabrics. Full product details, as set forth in the Exhibit, were provided.
Associations:
National Association of Textile Organizations
National Textile Association
American Manufacturing Trade Action Coalition
Contacts:
Michael Hubbard ()
David Trumbull (dtrumbull@national textile.org)
Augustine Tantillo ()
Sarah Ormond ()
Lloyd Wood ()
Page 2 of 16
COLUMBIA SPORTSWEAR
Mr. R. Matthew Priest, Chairman
December 21, 2007
Initial Contact/Date: 05/10/07 Inquiry regarding members’ ability to produce subject merchandise.
Response/date: NCTO replied that it believed Russ Knits and Beverly Knits could produce the subject merchandise. These companies were separately contacted.
7/16/07: Advised of modifications to fabric specifications
7/17/07: NCTO replied that several companies could perform certain aspects of the production process. Each company listed on the NCTO message was separately contacted. (see below)
Association: Nicaraguan Textile & Apparel Association
Contact/Email: ()
Initial Contact/Date/Substance: 05/23/07 Requested contact information for members capable of producing subject fabric.
Second Contact/Date: 05/29/27 Second request
Response/Date: No responses received
Association: Guatemala Apparel and Textile Association / VESTEX
Contact/Email: Irene Gonzalez/()
Initial Contact/Date/Substance: Association previously provided a list of fabric manufacturers. Those with an apparent potential to produce the subject fabric were separately contacted. (See below)
Association: Honduran Manufacturers Association
Contact/Email: Angela Castillo /
Initial Contact/Date/Substance: A list of Honduran fabric manufacturers was previously obtained from the Association. Those with an apparent potential to produce the subject fabric were separately contacted (See below)
Association: Adozona
Contact/Email: José M. Torres/ ()
Initial Contact/Date/Substance: 05/23/07 Contact information for members capable of producing subject fabric
Response/Date: 5/24/07: There is no commercial production of fabrics in Dominican Republic.
Company: UNITEX
Contact/Email:
Initial Contact/Date/Substance: May 29th 2007 / Inquiry regarding ability to produce subject merchandise
Second Contact: 05/30/07/ Second request.
Response/Date/Substance: No responses received.
Companies:
United States:
Firm: Copland Fabrics
Contact: Jason Copland ()
Contact date: 07/20/07 / Inquiry regarding ability to produce subject merchandise as amended
Response/date: 07/23/07: Company stated it could produce face fabric.
Follow Up: 09/4/7: Requested clarification that they could produce entire fabric within DR-CAFTA region.
Response: 09/6/7: Copland advised that it was not Copland’s “problem” to locate producers of knit face.
10/12/07: Doug Lumb of Polartec contacted Copland Sales Department and was told that Copland could not produce subject merchandise.
Firm: Milliken & Co.
Contact: Kathi Dutilh ()
Contact date: 05/10/07/ Inquiry regarding ability to produce subject merchandise
Response/date: 06/20/07/Company could make the two fabrics, but does not produce either now. Further, company could not bond two faces together.
07/16/07: Advised of modifications to fabric specifications
Response: 07/16/07: Company cannot make the fabric.
Additional response: 07/17/07. Company could produce fabric, but is not in a position to oppose.
Firm: Burlington WorldWide
Contact: Mike Vecchione ()/ Pat Palmer (()
Contact date: 07/27/07: Inquiry regarding ability to produce subject fabric.
08/13/07 - Original inquiry forwarded to Pat Palmer of Burlington WW.
Response: 08/21/07 – Advised Burlington is capable of manufacturing face fabric and confirmed Malden Mills (Polartec) is capable of manufacturing base fabric and combining layers as requested.
Reply: 08/21/07 - Request for sample conforming exactly to the parameters set forth in the published notice.
Response: 08/22/07 – Affirmed Burlington in conjunction with Malden Mills/Polartec is capable and interested in pursuing opportunity. Burlington requested that Columbia initiate direct contact to discuss product details and development requirements.
10/8/07: Burlington advised potential partner Polartec that its wovens were off sale (see below).
Firm: Polartec (formerly Malden Mills)
Contact: Moshe Rock –
Doug Lumb –
Contact date: Contact initiated by Burlington circa 8/22.
08/23/07 – Jeff Tooze of Columbia Sportswear teleconference with Moshe Rock confirming sample needs and address for package.
08/28/07: Fabric requirement document sent, specifying fabric quantities and deadlines. (
09/5/07: Request for estimated date of production samples
09/20/07: Request for estimated date of production samples
09/28/07: Telephone and email request for estimated date of production samples
10/8 – Moshe Rock / Polartec advised project was immediately transferred to Doug Lumb, SVP of Development.
10/8/07 – Polartec was informed by Burlington that the woven fabric was “off sale”, forcing him to source a new supplier. Polartec reported having difficulty sourcing woven fabric within DR-CAFTA region, resulting in the need to revise the purchase schedule for weave, dye and finish. Anticipated finished sample delivery by 10/19.
10/10/07: Teleconference with Doug Lumb. Polartec again advised that is had experienced delays in obtaining woven fabric face and could not currently identify a DR-CAFTA supplier that was capable of performing the embossing . Representative also stated that Polartec was the only U.S. company that could produce the fabric.
10/12/07: Provided D. Lumb with Columbia’s Methods and Standards packet provided to new vendors. Also suggested Polartec contact Copland Fabrics with as a potential source for woven face.
10/12/07: Polartec advised Columbia to expect sample by 10/19 with testing results to follow.
10/17/07 – D. Lumb reported sending specification and spoke with sales of Copland Fabrics. Copeland’s response was they could not make the fabric. Further confirmed the woven fabric from another vendor had been received and would be laminated that same day with knit fleece fabric component. Polartec does not emboss, but pursuing with Hornwood who has in-house embossing capability.
11/1/07: Polartec provided test results on thickness shrinkage, stretch, washfastness, crocking, water repellency, air permeability, abrasion. Polartec advised that it had discontinued further testing due to impression of discontinued interest in the program.
11/6/07: Columbia advised that it remained interested in the program and that Polartec should continue with testing in accordance with original agreed plan. Again requested remaining test results.
11/7/07: Polartec requested clarification of testing requirements.
12/10/07: Advised Polartec of major discrepancies with sample fabric. Requested follow up on contacts with Copland Fabrics. Requested status of attempts and tests on embossing and printing.
12/11/07: Polartec advised that Copland did not have current ability to produce woven face fabric; stated that they did not realize knit face required embossing and printing.
12/14/07: Columbia advised Polartec of its doubts that Polartec would be able to deliver the required fabric in the stated time frames.
Firm: Russ Knits
Contact: David Martin/
Contact date: 05/18/07 / Inquiry regarding ability to produce subject merchandise
06/20/07: Follow up
Response/date: June 21/Company can only produce backing fabric on contract.
07/16/07: Advised of modifications to fabric specifications
Firm: Beverly Knits
Contact: Mr. R. Sytz ()
Contact Date: 07/6/7: Inquiry regarding ability to produce subject.
Response: 07/15/07: Company advised that it could make the back fabric.
07/16/07: Advised of modifications to fabric specifications and requested information regarding the company’s ability to produce the entire fabric, or to provide information on potential partner companies to assist in the production of the fabric.
Firm: United Knitting
Contact: Jerry Miller/Fax: 423.472.9889
Contact date: 07/20/07: Inquiry regarding ability to produce subject merchandise as amended
Response/date: 07/23/07: Walter Tkach claimed that United Knitting could produce the knit fabric, but was not capable of printing, embossing, or laminating the fabric. He was not aware of several characteristics of the fabric, including whether it was stretch or not. He advised that he would provide a proposal via return email. None received.
Firm: Schneider Mills
Contact: Hank Boyd/Fax: 828.632.9834
Contact date: 07/20/07 / Inquiry regarding ability to produce subject merchandise as amended
Response/date: None received.
Firm: Precision Fabrics
Contact: Traci Broughton/
Contact date: 07/20/07 / Inquiry regarding ability to produce subject merchandise as amended
Response: 07/23/07. Advised Precision was able to produce the woven face fabric.
Reply: 09/04/07: We advised Precision that the entire fabric needed to be sourced in the DR-CAFTA region and requested on their ability to partner with other DR-CAFTA companies to produce fabric.
Response: 09/21/07: Company is not interested in developing new product.
Firm: Bloomsburg Mills , Inc.
Contact: William Parker/Fax: 570.784.8098
Contact date: 07/20/07 / Inquiry regarding ability to produce subject merchandise as amended
Response/date: None received.
Firm: Ramsay Fabrics
Contact: via website/
Contact date: 07/20/07 Inquiry regarding ability to produce subject merchandise as amended
Response/date: None received.
Firm: Amerbelle Textiles, LLC
Contact: Bill Horowitz/Art Aldrich (; )
Contact date: 7/25/07: Inquiry regarding ability to produce subject merchandise as amended
Response/date: 8/15/07: Company advised that it was not able to produce fabric; suggested Malden Mills/Polartec, which was separately contacted.
Firm: Saxon/Duro Textiles
Contact: Gail Strickler ()
Contact date: 7/24/07: Inquiry regarding ability to produce subject merchandise as amended
Response/date: 8/16/07: Company advised that it was not able to produce fabric.
Honduras:
Company: AKH
Contact/Email: Tem Mclnville ()
Initial Contact/Date/Substance: 05/23/07/ Inquiry regarding ability to produce subject merchandise.
Response/Date: 05/25/07 Company is not accepting orders.
Company: Caracol Knits
Contact/Email/Fax: Erick Rodriguez () (504) 507-1201
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise. (#11A) Recipient’s email servers would not allow delivering of message
Second Contact/Date: 05/23/07 - Recipient’s email servers would not allow delivering of message
Third Contact/Date: 05/23/07- Contacted via fax:
Fourth Contact/Date: 06/01/07 - Contacted via fax
07/16/07: Advised of modifications to fabric specifications Fax number provided by association does not work.
Response/Date: No response received.
Company: Coral Knits
Contact/Email: Gerson Fajardo ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.
Second Contact: 05/25/07 - Second Request.
07/16/07: Advised of modifications to fabric specifications
Response/Date: No response received.
Company: Cotton wise Textiles
Contact/Email/Fax: Mu Hyun Han () (504)554-0882
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.
Second Contact/Date: 05/25/07 Second request.
Third Contact/Date: 05/29/07 - Contacted via fax
07/16/07: Advised of modifications to fabric specifications. Fax number provided by association does not work.
Response/Date: No response received
Company: ELCATEX
Contact/Email/Fax: Jesus Canahuati ()/ (504)669-5167
Initial Contact/Date/Substance: Contacted via fax
07/16/07: Advised of modifications to fabric specifications
Response/Date: No response received.
Company: Gildan Activewear Honduras Textile Company
Contact/Email: Antonio Hepburn ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.
Second Contact/Date: 05/25/07 - Second request.
07/20/07: Advised of modifications to fabric specifications
Response/Date: No response received.
Company: Industrias Continental
Contact/Email: Roberto Diban Canahuati ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.
Response/Date: 05/23/07 - Company only produces knit fabric 100% cotton.
07/16/07: Advised of modifications to fabric specifications
Response/Date: 07/17/07: Company cannot produce subject merchandise as amended.
Company: RLA Manufacturing
Contact/Email: Philip Holloway ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.
Second Contact/Date: 05/25/07 - Second request.
07/16/07: Advised of modifications to fabric specifications
Response/Date: No response received.
Company: Shin Sung Honduras
Contact/Email: Jeong Yang Gi ()
Initial Contact/Date/Substance: May 23rd 2007 - Inquiry regarding ability to produce subject merchandise.
Response/Date: May 24th 2007 Company cannot produce subject merchandise.
7/16/07: Advised of modifications to fabric specifications
Response/Date: No response received.
Company: Sky Textile Honduras
Contact/Email: Ken Tai ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry () regarding ability to produce subject merchandise.
Second Contact/Date: 05/25/07 - Second request.
Response/Date: 05/25/07 - Mill has shut down.
Company: Textiles Rio Lindo
Contact/Email: Karen Facusse ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.
Response/Date: 05/23/07 Company cannot produce subject merchandise.
07/16/07: Advised of modifications to fabric specifications
Response/Date: 07/16/07: Company cannot produce subject merchandise as revised.
Company: Woong Chun Honduras
Contact/Email: Brian Kwon ()
Initial Contact/Date/Substance: May 23rd 2007 - Inquiry regarding ability to produce subject merchandise.
Second Contact/Date: 06/01/07 - Second contact.
07/16/07: Advised of modifications to fabric specifications
Response/Date: No responses received.
Company: Yangtex
Contact/Email/Fax: Fernando Yang () (504)672-1701
Initial Contact/Date/Substance: 05/23/07- Inquiry regarding ability to produce subject merchandise. (#22A) Recipient’s email servers would not allow delivering of message
Second Contact/Date: 05/23/07 Contacted via fax: Fax number provided by association is not in operation.
Comment: During previous investigations, Honduran Manufacturers Association advised company was going through a “system change” and was not accepting orders.
Guatemala:
Company: Alcatextil
Contact/Email: Ana Santos ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.
Second Contact/Date: 05/25/07 - Second contact.
07/16/07: Advised of modifications to fabric specifications
Response/Date: No response received.
Company: ARSA / Algodonera Retalteca
Contact/Email: Rocio Ralda ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.
Second Contact/Date: 06/01/07 - Second contact.
07/16/07: Advised of modifications to fabric specifications
Response/Date: No response received.
Company: Broadcloth
Contact/Email: Wilfredo Garcia Sanchez ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.
Second Contact/Date: 06/01/07 - Second contact.
Response/Date: No response received.
Company: Confecciones Anice/Conamsa
Contact/Email: Munir Massis (); ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.
Second Contact/Date: 06/01/07 - Second contact.
07/16/07: Advised of modifications to fabric specifications
Response/Date: No response received.
Company: Fabrica De Tejidos Iris
Contact/Email: Julio Farrach ()
Initial Contact/Date/Substance: 05/23/07 - Inquiry regarding ability to produce subject merchandise.