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Dear Chairman Shaw:


This letter is being written in response to your request for comments on the impact of suspending duties on certain acrylic/modacrylic yarn as proposed in H.R. 2591. The duty on the yarn in question currently stands at 9 percent, but H.R. 2591 proposes to take that duty to zero. The yarn in question is classified under USHTS subheading 5509.31.00, defined as "Yarn (other than sewing thread) of synthetic staple fibers, not put up for retail sale: Containing 85 percent or more by weight of acrylic or modacrylic staple fibers: Single yarn," contained in Category 604. Having analyzed this market, NCTO has come to the conclusion that suspending or eliminating the 9 percent duty on acrylic/modacrylic yarns would devastate the domestic producers of these products in a short time.


Domestic Production of Acrylic/Modacrylic Yarn
Given the large amount of acrylic/modacrylic yarn produced in the United States, we were surprised by this particular piece of legislation. The chart below provides production quantities for acrylic and modacrylic yarns for the last few years. The fact that the Census data do not break out single and plied yarn is immaterial since plied yarns are formed by twisting single yarn strands. A producer can sell yarn as a single (5509.31.0000) or a plied (5509.32.0000) according to customer demand.


Census quit reporting sales yarn production with the 2003 data, but most production is sold on the open market. Despite declines in production in recent years, the industry still is able to produce a massive quantity of the subject product. The decline in domestic acrylic/modacrylic yarn production is attributable largely to increased foreign competition. Another obstacle facing producers is the closure of the last acrylic fiber production in the U.S. Producers are forced to pay duty on all acrylic/modacrylic fiber imports, and the yarns made from these fibers do not qualify for special duty treatment with our free trade agreement partners around the world except in Canada.

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