A Stitch in Trade: Section 304 of the Tariff Act of 1930 & The Substantial Transformation Rule in Apparel Manufacturing

Section 304 of the Tariff Act of 1930 might not sound like a fashion statement, but it plays a major role in what you wear—and where it's labeled as coming from. Essentially, this law mandates that any imported product must be marked with its country of origin so that consumers know exactly where their new favorite shirt (or pants, or shoes) came from. But like all things in global trade, it’s not quite that simple, thanks to the Substantial Transformation Rule.

Country of Origin vs Country of Production

A product may begin its life life in one country, say a sweat shop in Bangladesh, then flown to Italy where it legally gets a “Made in Italy” tag.

The Substantial Transformation Rule is the ultimate game of dress-up for manufacturers. It determines whether a product, say a simple fabric, gets a passport stamp from one country or another based on where the "significant" work happens. For example, if raw cotton is grown in one country but cut, dyed, and sewn into a trendy jacket somewhere else, the rule decides which country gets credit (and a "Made in [Country]" tag). So, the origin is not necessarily where the product started, but where it underwent its substantial makeover.

Made in America

A product needs to be 100% constructed here to have those 3 words sewn into it. The fabric and ingredients can be used from other countries, we are proudly transparent that the fabrics we use come from Italy, England and even America.

For apparel manufacturing, this rule creates a fun (or maddening) dance of international trade. Brands and manufacturers can assemble fabrics from various countries, process them elsewhere, and—voila!—the country that transforms the product the most gets to slap its name on the label. This can lead to cost savings and tariff advantages for companies, depending on where production steps occur.

In short, Section 304 ensures transparency, while the Substantial Transformation Rule gives apparel makers a clever way to manage supply chains, optimize costs, and navigate the wild world of international trade regulations—all while keeping your wardrobe fresh.