This is the accessible text file for GAO report number GAO-12-204R 
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GAO-12-204R: 

United States Government Accountability Office: 
Washington, DC 20548: 

November 30, 2011: 

The Honorable Max Baucus:
Chairman:
The Honorable Orrin G. Hatch:
Ranking Member:
Committee on Finance: 
United States Senate: 

The Honorable Dave Camp:
Chairman:
The Honorable Sander M. Levin:
Ranking Member:
Committee on Ways and Means: 
House of Representatives: 

Subject: Earned Import Allowance Program for Haiti: 

The United States has historically provided assistance to support 
development in Haiti. Over the last several years, Congress has 
attempted to promote Haiti's economic development through the use of 
trade preferences for Haitian products. In 2000, Congress extended 
preferences under the Caribbean Basin Economic Recovery Act[Footnote 
1] to allow for duty-free treatment of apparel through the Caribbean 
Basin Trade Partnership Act (CBTPA).[Footnote 2] In 2006, Congress 
passed the Haitian Hemispheric Opportunity through Partnership 
Encouragement (HOPE) Act, giving preferential access to U.S. imports 
of Haitian apparel.[Footnote 3] In 2008, Congress amended HOPE (now 
known as HOPE II), expanding trade preference provisions already in 
place and creating new ones to further support the growth of the 
apparel industry in Haiti.[Footnote 4] It was the intent of Congress 
that HOPE II would help Haiti attract new investment and create jobs 
while simultaneously providing incentives to encourage the use of 
inputs manufactured by U.S. companies. Most recently, in an effort to 
support Haiti's recovery from the devastating earthquake that hit the 
country in January 2010, Congress passed the Haiti Economic Lift 
Program (HELP) Act of 2010,[Footnote 5] expanding and modifying 
several trade preference provisions under HOPE II. The various 
provisions included under HOPE II and CBTPA offer different avenues 
through which qualifying apparel goods produced in Haiti can be 
exported to the United States duty-free. 

One trade preference provision originally created under HOPE II was 
the "3-for-1" Earned Import Allowance Program (EIAP). The provision 
under Hope II established that, for every 3-square-meter equivalent 
(SME) of qualifying fabric a firm imports to Haiti,[Footnote 6] the 
firm would be allowed to earn a credit to export 1 SME of apparel 
produced in Haiti to the United States, duty-free, regardless of the 
source of the fabric.[Footnote 7] In this way, EIAP was designed to 
both aid Haiti's apparel industry and encourage the use of U.S.-
manufactured inputs. The HELP Act reduced the EIAP exchange ratio from 
3-for-1 to 2-for-1. The change sought to encourage the use of EIAP, 
since no apparel from Haiti was exported to the United States under 
the original 3-for-1 model. This report responds to a mandate in the 
Food, Conservation, and Energy Act of 2008, which requires GAO to 
review EIAP annually and conduct an evaluation of the program. We 
issued our first report under this mandate in June 2010, focusing on 
EIAP as it existed during the period of our first review, from October 
2009 to June 2010, at which time it featured the 3-for-1 exchange 
ratio.[Footnote 8] That report also included a more complete 
discussion of HOPE II and CBTPA preference provisions. In this report, 
we assess the extent to which EIAP has been used since it was amended 
under the HELP Act--signed into law on May 24, 2010. 

To address this question, we reviewed data provided by the Department 
of Commerce's (Commerce) Office of Textiles and Apparel (OTEXA), which 
has responsibility for managing the Haitian EIAP. We interviewed 
cognizant OTEXA officials responsible for managing trade data. We 
discussed OTEXA's data collection and processing methods, and 
determined the data to be sufficiently reliable for the purposes of 
this report. For this report, we also conducted interviews with OTEXA 
officials and obtained written information from a representative of 
the one company that established an EIAP account since the program was 
amended in 2010. Through these sources, we identified the key elements 
of the program, the extent to which the program has been used, and 
some of the factors influencing the program's use. In our previous 
review of the Haiti EIAP, we met with EIAP account holders, Haitian 
industry representatives and associations, U.S. apparel buyers and 
associations, and a U.S. textile-manufacturing association; their 
views are included in this review as appropriate. We conducted this 
performance audit from September 2011 through November 2011 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Results in Brief: 

In 2011, for the first time since the program was established in 2008, 
one company has opted to use EIAP to export apparel from Haiti to the 
United States. The value of these exports (about $350,000) represents 
0.2 percent of total apparel exports under HOPE II, and only 0.07 
percent of total apparel exports from Haiti to the United States under 
all preference programs based on year-to-date data as of August 2011. 
Total apparel exports from Haiti to the United States, for the same 
period, were valued at about $465 million--approximately $140 million 
were exported under various provisions of HOPE II, including EIAP, and 
about $313 million were exported under CBTPA.[Footnote 9] Three other 
companies have established EIAP accounts, but not all of these 
accounts are being used to earn credits, and those with credits have 
not used them to export apparel from Haiti to the United States. The 
level of EIAP use continues to be modest due to the availability of 
other more flexible provisions. Apparel producers stated that they did 
not expect participation in EIAP to increase significantly unless 
certain provisions of HOPE II and the CBTPA, which are subject to 
volume caps, begin to approach their limit. Furthermore, the use of 
the more flexible trade preferences under HOPE II and CBTPA has 
continued to increase, while little has been exported using EIAP. 
Exporters considered the other HOPE II provisions simpler and more 
advantageous because firms can import most types of apparel duty-free, 
regardless of the fabric's source, without being required to purchase 
any kind of qualifying inputs or to register for a program. 

Background: 

At its peak in the 1980s, Haiti had a well-established garment 
assembly industry that employed more than 100,000 people. However, 
global economic forces and a series of violent internal political 
struggles in the 1980s and 1990s nearly decimated the industry. 
Nevertheless, production in the apparel sector in Haiti began 
increasing steadily during the past decade, with Haitian apparel 
exports to the United States growing from $251 million in 2000 to $518 
million in 2010. The Haitian government considers the apparel industry 
an engine of economic growth and job creation. 

After the January 2010 earthquake, concerns arose that damage to 
apparel production plants and an already poor infrastructure, 
particularly Haiti's roads and port facilities, would be a major 
setback for the country's progress in apparel production. However, 
while the damage caused by the earthquake brought apparel production 
in Haiti to a halt, by March 2010 there were signs that production had 
been restored. U.S. imports of apparel from Haiti began to recover 
soon after the earthquake, reaching $80 million in June 2011, as shown 
in figure 1. Further, from 2009 to 2010, even with the damage from the 
earthquake, U.S. imports of apparel from Haiti increased from $513 to 
$518 million. Notably, during the 12 months ending in August 2011, 
imports of textiles and apparel increased 50 percent over the same 
period a year earlier. 

Figure 1: U.S. Monthly Imports from Haiti, January 2009 through August 
2011: 

[Refer to PDF for image: stacked line graph] 

Date: January 2009; 
Textile and apparel goods: $19.3 million; 
Other: $1.9 million. 

Date: February 2009; 
Textile and apparel goods: $39.1 million; 
Other: $1.6 million. 

Date: March 2009; 
Textile and apparel goods: $43.0 million; 
Other: $1.9 million. 

Date: April 2009; 
Textile and apparel goods: $39.7 million; 
Other: $4.1 million. 

Date: May 2009; 
Textile and apparel goods: $44.5 million; 
Other: $7.4 million. 

Date: June 2009; 
Textile and apparel goods: $53.4 million; 
Other: $3.8 million. 

Date: July 2009; 
Textile and apparel goods: $50.2 million; 
Other: $5.0 million. 

Date: August 2009; 
Textile and apparel goods: $46.3 million; 
Other: $5.2 million. 

Date: September 2009; 
Textile and apparel goods: $47.7 million; 
Other: $2.2 million. 

Date: October 2009; 
Textile and apparel goods: $42.6 million; 
Other: $2.2 million. 

Date: November 2009; 
Textile and apparel goods: $44.4 million; 
Other: $1.9 million. 

Date: December 2009; 
Textile and apparel goods: $44.4 million; 
Other: $4.5 million. 

Date: January 2010; 
Textile and apparel goods: $59.8 million; 
Other: $6.7 million. 

[Earthquake, January 12] 

Date: February 2010; 
Textile and apparel goods: $27.4 million; 
Other: $2.1 million. 

Date: March 2010; 
Textile and apparel goods: $43.2 million; 
Other: $1.6 million. 

Date: April 2010; 
Textile and apparel goods: $44.7 million; 
Other: $1.6 million. 

Date: May 2010; 
Textile and apparel goods: $43.5 million; 
Other: $3.5 million. 

Date: June 2010; 
Textile and apparel goods: $54.5 million; 
Other: $6.7 million. 

Date: July 2010; 
Textile and apparel goods: $45.7 million; 
Other: $5.2 million. 

Date: August 2010; 
Textile and apparel goods: $48.6 million; 
Other: $2.9 million. 

Date: September 2010; 
Textile and apparel goods: $58.3 million; 
Other: $2.4 million. 

Date: October 2010; 
Textile and apparel goods: $49.9 million; 
Other: $2.0 million. 

Date: November 2010; 
Textile and apparel goods: $44.2 million; 
Other: $2.2 million. 

Date: December 2010; 
Textile and apparel goods: $53.7 million; 
Other: $2.6 million. 

Date: January 2011; 
Textile and apparel goods: $32.5 million; 
Other: $2.0 million. 

Date: February 2011; 
Textile and apparel goods: $56.2 million; 
Other: $2.2 million. 

Date: March 2011; 
Textile and apparel goods: $62.0 million; 
Other: $2.3 million. 

Date: April 2011; 
Textile and apparel goods: $55.2 million; 
Other: $5.8 million. 

Date: May 2011; 
Textile and apparel goods: $62.2 million; 
Other: $6.3 million. 

Date: June 2011; 
Textile and apparel goods: $72.1 million; 
Other: $5.1 million. 

Date: July 2011; 
Textile and apparel goods: $67.2 million; 
Other: $2.4 million. 

Date: August 2011; 
Textile and apparel goods: $69.6 million; 
Other: $4.0 million. 

Source: GAO analysis of OTEXA data. 

[End of figure] 

EIAP is one of several trade preference provisions created under HOPE 
II and amended under HELP. As with other preferences, EIAP was meant 
to help the industry by providing incentives for apparel production in 
Haiti and encouraging the use of U.S.-manufactured inputs. In addition 
to EIAP, HOPE II also includes five other provisions allowing for the 
duty-free treatment of certain qualifying Haitian-produced apparel, 
including the Value-Added Restraint Limit, Woven Apparel Restraint 
Limit, Knit Apparel Restraint Limit, Certain Types of Apparel, and 
Apparel Made with "Short Supply" yarns or fabrics. Under HOPE II, 
these preferences were given a duration of 10 years and were set to 
expire in 2018; HELP extended them until September 2020. 

Commerce's OTEXA is responsible for the administration and management 
of the Haiti EIAP. As amended by HELP, under the Haiti EIAP, producers 
or other entities controlling production[Footnote 10] can qualify for 
a credit to export 1 SME of apparel produced in Haiti to the United 
Sates free of duty, if they import 2 SMEs of U.S. or other qualifying 
fabric.[Footnote 11] EIAP is administered through an online account 
mechanism in which firms can open an account, submit requests for 
credits on qualifying purchases, and deposit the credits for 
electronic storage. Subsequently, they can redeem those credits in the 
form of a certificate qualifying future apparel exports from Haiti to 
the United States for duty-free treatment, as shown in figure 2. 

Figure 2: Example of EIAP Transaction Process as Amended under the 
HELP Act: 

[Refer to PDF for image: illustration] 

Phase I: Credit earned by importing U.S. fabric to Haiti: 

Step 1. Firm opens account and imports 2 SMEs of qualifying fabric.  

Step 2. OTEXA confirms transaction and deposits 1 credit. This credit 
can be banked and used at the firm's discretion.  

Phase II: Credit used to export apparel to the United States: 
  
Step 3. Firm imports non-U.S. fabric from third country, e.g., China.  

Step 4. Non-U.S fabric is completely assembled into apparel in Haiti.  

Step 5. Firm uses credit to export 1 SME of this apparel to U.S., not 
normally given duty free treatment because it is made with non-U.S. 
fabric. 

Source: GAO analysis of information from OTEXA; Map Resources (maps). 

[End of figure] 

Exporters' Participation in EIAP Remains Modest Due to the 
Availability of Other, More Flexible Trade Preferences: 

The use of the Haiti EIAP continues to be modest, even after it was 
amended by the HELP Act of 2010 to a more advantageous "2-for-1" 
exchange ratio. To date, the Haiti EIAP has experienced little 
activity. Four accounts have been opened with OTEXA, but only one was 
opened after the program was amended under the HELP Act of 2010. Since 
the program was established in 2008, more than 13 million SMEs of 
qualifying fabric have been imported into Haiti under the program, 
resulting in almost 6 million credits for duty-free exports of apparel 
approved and deposited. However, according to OTEXA officials, not all 
accounts are being used to earn credits. Moreover, they explained that 
only one account holder has redeemed credits to export apparel under 
the program. From January through August 2011, OTEXA reported that 
about $350,000 in apparel had been exported from Haiti to the United 
States under EIAP, out of a total of $465 million in apparel exported 
from Haiti to the United States during the same period, including $140 
million exported under HOPE II[Footnote 12]. Thus, Haitian apparel 
exports under EIAP represented only about 0.07 percent of total 
Haitian apparel exports to the United States, and 0.2 of apparel 
exports under HOPE II. 

According to OTEXA, the other three account holders may not be using 
EIAP credits because they prefer to export their products under other 
provisions of U.S. trade preference programs for Haiti, including HOPE 
II and the CBTPA. OTEXA suggests that these companies may be using the 
Woven and Knit Apparel Restraint Limit programs to export their 
garments to the United States because these provisions allow Haitian 
apparel made with third-country fabric to enter duty-free without the 
need to earn or use credits. A representative from the company that 
opted to use EIAP to export apparel from Haiti to the United States 
explained that the company has a high volume of qualifying U.S. 
exports to Haiti that allow it to earn credits under the program, 
providing an incentive to use EIAP. Additionally, this individual 
commented that the program, as it is administered by Commerce, is 
transparent and ensures a predictable means of exporting to the United 
States. He noted that the company expects to continue exporting under 
the program. The other account holders have told us that they intend 
to hold on to the credits until it becomes necessary to use them, for 
instance, if certain provisions of HOPE II and the CBTPA, which are 
subject to volume caps, begin to approach their limit. They have 
continued exporting apparel duty-free to the United States under the 
HOPE II provisions discussed above and have not needed to use credits 
earned under EIAP. 

Apparel Imports under Other Provisions of HOPE II and CBTPA Increased 
Substantially Over the Past 5 Years: 

While use of EIAP continues to be very modest, exports under other 
HOPE and HOPE II provisions have increased substantially over the past 
5 years and CBPTA continues to be the most common trade preference 
used to export Haitian apparel to the United States. The primary 
provisions used under HOPE II and CBTPA are the HOPE II Knit Apparel 
and Woven Apparel Restraint Limit provision, and the CBTPA T-shirt 
Restraint Limit program. The HOPE II Value-Added Restraint Limit rule 
has also been used extensively, but its use has decreased in recent 
years.[Footnote 13] 

Exports under HOPE and subsequently HOPE II have grown steadily from 
$13.7 million in 2007 to almost $160 million in 2010, and were about 
$140 million from January to August, 2011. Producers consider Woven 
Apparel Restraint Limit, and Knit Apparel Restraint Limit programs to 
be simpler than EIAP and, more importantly, more flexible because they 
allow for fabric inputs from any source without being required to 
purchase any kind of qualifying inputs or to register for a program. 

* Value-Added Restraint Limit: Most HOPE and HOPE II exports have 
entered under the Value-Added Restraint Limit rule, but the share of 
imports under this rule show a decreasing trend over the last 5 years. 
Specifically, the percentage of apparel under HOPE and HOPE II that 
was exported under the value-added rule has decreased from 89 percent 
in 2007 to 46 percent in 2010, and is down to about 37 percent based 
on year-to-date data through August 2011. This decrease occurred in 
part because exporters have increasingly chosen to export apparel 
under HOPE II's woven duty-free provisions, which do not have value-
added requirements, such as restrictions on the amount of inputs that 
must be sourced from specified countries. 

* Woven Apparel Restraint Limit: The woven apparel duty-free provision 
of HOPE II accounts for a significant portion of apparel exports from 
Haiti. Based on year-to-date figures through August 2011, 46 percent 
of apparel exports under HOPE II entered the United States under the 
woven apparel provision, which allows the use of third-country fabric, 
without having to include any U.S. or regionally produced inputs. 
Under HOPE II, the woven provision was limited by an annual cap known 
as a Tariff Preference Level (TPL) that was set at 70 million SMEs; 
the HELP Act of 2010 increased the TPL to 200 million SMEs. In the 
period from January through August 2011, about 16 million SMEs of 
woven apparel were exported under the Woven Apparel Restraint Limit, 
thus far reaching only 8 percent of the 200 million SMEs limit. 

* Knit Apparel Restraint Limit: Although the knit apparel duty-free 
provision accounted for only 11 percent of apparel exports under HOPE 
II in 2010, use of this provision experienced significant increase 
since 2009. Exports under this provision almost tripled from $6.6 
million in 2009 to $18.3 million in 2010, and during 2011 have already 
exceeded last year's amount, reaching $22.6 million and accounting for 
16 percent of exports under HOPE II through August. The knit provision 
was also initially capped by an annual TPL of 70 million SMEs, and was 
later increased by the HELP Act to 200 million SMEs. In the period 
from January through August 2011 about 18 million SMEs of knit apparel 
have been exported under the Knit Apparel Restraint Limit, thus far 
reaching only 9 percent of the 200 million SMEs limit. Table 1 shows 
the level of imports under various HOPE and HOPE II provisions. 

Table 1: U.S. Imports of Apparel from Haiti under HOPE and HOPE II, 
2007-August 2011: 

Dollars in millions: 

Provision: Value-Added Restraint Limit; 
2007 (HOPE) Annual value: $12.2; 
2007 (HOPE) Percent: 89; 
2008 (HOPE II) Annual value: $47.8; 
2008 (HOPE II) Percent: 64; 
2009 (HOPE II) Annual value: $67.3; 
2009 (HOPE II) Percent: 49; 
2010 (HOPE II) Annual value: $74; 
2010 (HOPE II) Percent: 46; 
2011 (HOPE II) Annual value: $52; 
2011(HOPE II) through August: Percent: 37. 

Provision: Woven TPL; 
2007 (HOPE) Annual value: $1.5; 
2007 (HOPE) Percent: 11; 
2008 (HOPE II) Annual value: $27; 
2008 (HOPE II) Percent: 36; 
2009 (HOPE II) Annual value: $63.9; 
2009 (HOPE II) Percent: 46; 
2010 (HOPE II) Annual value: $67.5; 
2010 (HOPE II) Percent: 42; 
2011 (HOPE II) Annual value: $65.1; 
2011(HOPE II) through August: Percent: 46. 

Provision: Knit TPL; 
2007 (HOPE) Annual value: n/a; 
2007 (HOPE) Percent: [Empty]; 
2008 (HOPE II) Annual value: $0.14; 
2008 (HOPE II) Percent: 0.2; 
2009 (HOPE II) Annual value: $6.6; 
2009 (HOPE II) Percent: 5; 
2010 (HOPE II) Annual value: $18.3; 
2010 (HOPE II) Percent: 11; 
2011 (HOPE II) Annual value: $22.6; 
2011(HOPE II) through August: Percent: 16. 

Provision: EIAP; 
2007 (HOPE) Annual value: n/a; 
2007 (HOPE) Percent: [Empty]; 
2008 (HOPE II) Annual value: $ 0; 
2008 (HOPE II) Percent: Empty]; 
2009 (HOPE II) Annual value: $0; 
2009 (HOPE II) Percent: [Empty]; 
2010 (HOPE II) Annual value: $0; 
2010 (HOPE II) Percent: [Empty]; 
2011 (HOPE II) Annual value: $0.35; 
2011(HOPE II) through August: Percent: 0.2. 

Provision: Other[A]; 
2007 (HOPE) Annual value: n/a; 
2007 (HOPE) Percent: [Empty]; 
2008 (HOPE II) Annual value: $ 0; 
2008 (HOPE II) Percent: [Empty]; 
2009 (HOPE II) Annual value: $0.6; 
2009 (HOPE II) Percent: 0.004; 
2010 (HOPE II) Annual value: $0; 
2010 (HOPE II) Percent: [Empty]; 
2011 (HOPE II) Annual value: $0; 
2011(HOPE II) through August: Percent: [Empty]. 

Provision: Total U.S. HOPE and HOPE II imports; 
2007 (HOPE) Annual value: $13.7; 
2007 (HOPE) Percent: 100; 
2008 (HOPE II) Annual value: $74.9; 
2008 (HOPE II) Percent: 100; 
2009 (HOPE II) Annual value: $137.9; 
2009 (HOPE II) Percent: 100; 
2010 (HOPE II) Annual value: $159.8; 
2010 (HOPE II) Percent: 100; 
2011 (HOPE II) Annual value: $140.1; 
2011(HOPE II) through August: Percent: 100. 

Source: GAO analysis of OTEXA calendar-year data. 

Notes: Table includes data on imports under the initial HOPE program, 
amended in 2008 and now referred to as HOPE II. "The Knit TPL," 
"EIAP," "Certain Articles," and "Short Supplies" provisions were 
passed in 2008 under HOPE II, and were unavailable in 2007. 

Some percentage totals do not add to 100 percent because of rounding. 

[A] Includes duty-free treatment of "Certain Articles" and articles 
made with materials in "Short Supply" from U.S. or other trade 
partners. 

[End of table] 

While exports under HOPE II have grown significantly since its 
inception in 2008, CBTPA continues to be the most common trade 
preference used to export Haitian apparel to the United States. In 
2010, more than $350 million in apparel was exported from Haiti to the 
United States under CBTPA. Apparel exports under CBTPA reached more 
than $313 million in the period from January through August 2011, 
accounting for more than two-thirds of the value of all Haitian 
apparel exported to the United States. CBTPA has played an important 
role in sustaining the Haitian apparel industry, since it supports the 
production of knits. CBTPA continues to be heavily used, in part 
because certain men's and boys' T-shirts are specifically excluded 
from the knit TPL under HOPE II. CBTPA allows T-shirts to be assembled 
in Haiti with fabric produced in the Dominican Republic, or other 
parts of the region, made with U.S. yarns. T-shirts and sweatshirts 
are the most common garments produced in Haiti and exported to the 
United States. Since the implementation of the Dominican Republic-
Central America-United States Free Trade Agreement, Haiti has become 
the major beneficiary of preferences for apparel under the CBTPA. 
[Footnote 14] 

Agency Comments: 

We requested comments on a draft of this report from OTEXA at the 
Department of Commerce. The Department of Commerce generally concurred 
with the draft report and stated that it is pleased by the growing 
usage of the EIAP benefits, and that it anticipates greater interest 
in the program from U.S. importers, brands and retailers. OTEXA also 
provided technical comments, which were incorporated in the report as 
appropriate. 

We are sending copies of this report to appropriate congressional 
committees and the Secretary of Commerce. This report will also be 
available at no charge on GAO's Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-4347 or yagerl@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. Key contributors to this report were 
Juan Gobel, Assistant Director; Francisco M. Enriquez; and Gezahegne 
Bekele. 

Signed by: 

Loren Yager:
Director:
International Affairs and Trade: 

[End of section] 

Footnotes: 

[1] In 1983, Congress passed the Caribbean Basin Economic Recovery Act 
(Public Law 98-67, Title II) to allow for duty-free treatment of most 
goods, including certain apparel, exported from Haiti and other 
Caribbean Basin countries to facilitate the economic development and 
export diversification of these economies. 

[2] Public Law 106-200, Title II. 

[3] Public Law 109-432, Div. D, Title V. 

[4] Haitian Hemispheric Opportunity through Partnership Encouragement 
Act of 2008 (HOPE II), Public Law 110-234, Title XV, Subtitle D, Part 
I. 

[5] Public Law 111-171 H.R. 5160, 111th Cong., 2d Sess. 

[6] Qualifying woven fabric is wholly formed in the United States from 
yarns wholly formed in the United States. Qualifying knit fabric, or 
knit-to-shape components, are wholly formed or knit to shape in the 
United States, specified Free Trade Agreement partner countries, or 
countries designated as beneficiaries of certain trade preference 
programs, from yarns wholly formed in the United States. 

[7] For example, if a firm bought 300 SMEs of U.S.-woven fabric for 
apparel production in Haiti, it would earn credits that would allow it 
to export 100 SMEs of apparel made from fabric manufactured in another 
country, such as China, to the United States duty-free. 

[8] GAO, International Trade: Exporters' Use of the Earned Import 
Allowance Program for Haiti Is Negligible because They Favor Other 
Trade Options, [hyperlink, http://www.gao.gov/products/GAO-10-654], 
(Washington D.C.: June 16, 2010). 

[9] There were also about $12 million in apparel exports from Haiti to 
the United States that did not enter under the trade preference 
provisions of HOPE II or CBTPA. 

[10] Entities eligible to use the program are referred to as 
Qualifying Apparel Producers. Such an entity is defined as an 
individual, corporation, partnership, association, or other entity or 
group that exercises direct, daily operational control over the 
apparel production process in Haiti, or an individual, corporation, 
partnership, association, or other entity that is not a producer and 
that controls the apparel production process in Haiti through a 
contractual relationship or other indirect means. 

[11] Qualifying woven fabric is wholly formed in the United States 
from yarns also wholly formed in the United States. Qualifying knit 
fabric, or knit to shape components, are wholly formed or knit to 
shape in the United States, specified Free Trade Agreement partner 
countries, or countries designated as beneficiaries of certain trade 
preference programs, from yarns wholly formed in the United States. 

[12] At the time of our review, August 2011 was the last month for 
which OTEXA had recorded data on exports from Haiti to the United 
States. 

[13] In addition to EIAP, there are two other provisions of HOPE II 
which were generally not used to export apparel from Haiti to the 
United States in 2010. These two provisions are known as "Duty-Free 
Treatment of Certain Articles" and "Short Supply." Duty-Free Treatment 
of Certain Articles refers to articles, such as brassieres, luggage, 
headwear, and certain sleepwear, that qualify for duty-free treatment 
as long as they are wholly assembled or knit to shape in Haiti and 
they are imported directly from Haiti or the Dominican Republic to the 
United States. There are no restrictions on the source of inputs used 
for these products. Short Supply refers to any apparel wholly 
assembled or knit to shape in Haiti that is made of fabric, 
components, or yarns deemed to be in short supply as defined in all 
other preference arrangements and Free Trade Agreements of the United 
States that qualify for duty-free treatment. 

[14] Haiti's share of apparel exports to the United States under the 
CBTPA provision for duty-free treatment of knit apparel has grown from 
5.4 percent in 2005 to 100 percent in 2009. Similarly, Haiti's share 
of apparel exports to the United States under the CBTPA provision for 
duty-free treatment of T-shirts has grown from 3.1 percent in 2005 to 
100 percent in 2009. The caps on these preferences are 970 million SME 
for knit apparel, of which 14.8 percent was filled in 2009, and 12 
million dozen T-shirts, of which of 63.5 percent was filled in 2009. 
Haiti's dominance of apparel exports to the United States under CBTPA 
since 2009 is due to the fact that former CBTPA beneficiaries have 
joined the Dominican Republic-Central America-United States Free Trade 
Agreement and no longer qualify for CBTPA preferences. 

[End of section] 

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