The American Apparel & Footwear Association (AAFA) has urged the Office of the U.S. Trade Representative not to impose additional tariffs on footwear imported from Brazil, warning that the sector is already among the most heavily taxed categories in U.S. trade.
Beth Hughes, AAFA’s vice president of trade and customs policy, delivered the testimony at a USTR hearing this week as part of the agency’s Section 301 investigation into Brazil’s trade practices, which spans issues from digital trade and preferential tariffs to anti-corruption enforcement and illegal deforestation. Hughes focused her remarks narrowly on footwear, arguing that adding new duties on top of existing ones would compound a tariff burden that is already disproportionate to the industry’s size.
U.S. companies paid nearly $61 million in tariffs on footwear imported from Brazil in 2025 alone, according to figures Hughes cited in her testimony. Footwear faced an average trade-weighted tariff rate of 23.5% that year, roughly three times the 7.8% rate applied across all imported products. The gap underscores a longstanding complaint from AAFA and allied trade groups that apparel, footwear and travel goods are taxed at rates far exceeding the broader average, even as these categories make up a small share of total import value.
Brazil’s footwear shipments to the United States are heavily concentrated in leather goods, which accounted for nearly 72% of Brazilian footwear imports in 2025. Those leather shoe imports were valued at $157.7 million, representing 5.66 million pairs brought into the U.S. market last year. That concentration means any new tariff action targeting Brazil would land disproportionately on leather footwear makers and the retailers who source from them.
The hearing is one stage in a broader Section 301 probe that USTR opened last July into a range of Brazilian trade and policy practices, including what the agency has characterized as unfair, preferential tariff treatment favoring other large trading partners such as India and Mexico over the United States. In 2024, Brazil’s simple average applied tariff rate stood at 12.2%, compared with 3.3% for the United States, a disparity that USTR has flagged as part of its case for possible retaliatory action.
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AAFA’s position reflects a pattern the group has pressed across multiple recent trade proceedings: that fashion products already shoulder outsized tariff costs relative to other consumer goods, and that further duties would raise costs for American businesses and consumers without addressing the underlying practices the investigation is meant to target. The association has made similar arguments in past testimony on Section 301 tariffs tied to China and in comments supporting duty-free access under the U.S.-Mexico-Canada Agreement.
Trade watchers say the Brazil case carries added weight given the current uncertainty surrounding U.S. tariff policy more broadly. Section 122 tariffs are set to expire later this month unless Congress acts to extend them, and the fate of other tariff actions remains in flux following a Supreme Court ruling against tariffs imposed under the International Emergency Economic Powers Act earlier this year. For footwear importers already navigating that shifting landscape, AAFA argues, additional Brazil-specific duties would add another layer of unpredictability to sourcing decisions.
The USTR has not indicated when it expects to issue a final determination on the Brazil investigation or announce any resulting tariff action. Public comments and testimony from the hearing will factor into the agency’s next steps, alongside written submissions filed ahead of the July 1 deadline.
For now, AAFA’s message to USTR is that footwear should be treated as a case apart from the broader Brazil investigation, given the sector’s existing tariff exposure and its reliance on leather imports that have no significant domestic manufacturing alternative in the United States.