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10+2 Trade Rule
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December 15, 2008
10+2 Trade Rule
New data regulations being considered by the US government to help prevent terrorist weapons from being
transported to the US will have major implications for garment importers.
The Importer Security Filing and Additional Carrier Requirements, commonly known as 10+2, will require
importers to submit data on their shipments at least 24 hours before loading on an ocean carrier.
Details of the proposed rule were first published on January 2, 2008 but have since been amended, with a
'Final Interim Rule' coming into effect on January 26, 2009.
Under existing requirements, importers must file entry information with US Customs and Border Protection
(CBP) within 15 days of a shipment arriving at a US entry port, followed by summary information within 10 days of
Under the new plans, however, importers would have to file data no later than 24 hours before the cargo is
laden aboard a vessel destined to the US.
This applies to shipments of goods intended for the US or delivered to a foreign trade zone (FTZ).
The information that needs to be supplied covers ten areas.
Eight are applicable to importers: seller, buyer, importer of record
number/FTZ applicant identification number, consignee number(s), manufacturer (or
supplier), ship to party, country of origin, and commodity Harmonized Tariff Schedule of the United
States (HTSUS) number.
And two relate to suppliers and/or forwarders, who need to provide information on the container stuffing
location and the consolidator's name and address.
Importers will have 12 months after the final ruling takes effect to comply
fully, and during this period CBP will show restraint in enforcing it.
CBP says it will also check for any specific compliance difficulties that importers and shippers may experience
in submitting all data elements 24 hours before lading.
Obviously there are implications for re-engineering current business processes and systems.
Not only must data submissions be delivered to CBP via an approved electronic data interchange system, but
data from purchase orders, packing and shipping documents - which may be held by buyers, vendors,
manufacturers, agents, logistics service providers and factories - all needs to be easily accessible.
Invoice Checks on Pakistani
US customs officers in New York are more stringently
checking Pakistani garment imports amid suspicions their invoice value is more than the actual
They believe that Pakistani exporters might be trying to get undue benefits from the 6% R&D subsidy offered
by the Pakistani government on exports of knitted and woven garments by inflating invoice values.
However, Pakistan Readymade Garments Manufacturers & Exporters Association former chairman Ejaz Khokhar said
that the US authorities have not yet provided any evidence on the matter.
He also urged the government of Pakistan to intervene through the Embassy of Pakistan in Washington and the
Commercial Counselor in New York before the checks hold up exports any further.
Tia Lyn's NY Fashion Show with beautiful models of ALL SIZES!
OFT Warns UK Retailers
Retailers including Marks and Spencer and Arcadia Group and Marks and Spencer have reportedly been warned about
competition laws after they all agreed to drop prices in line with a 2.5% VAT cut in the UK.
The UK's Office of Fair Trading (OFT) surprised the retailers by sending them a letter on the matter.
Both M&S and Arcadia joined a swathe of retailers to immediately pass on the UK government's reduction in
VAT from 17.5% to 15% last month.
However, it was reported that a number of fashion retailers had issued a statement saying a joint
approach would help consumers most, which appears to have alerted the OFT.
A spokesperson for the OFT said: "The OFT has dialogue on a range of competition and consumer law matters with
a large number of companies, both in the retail field and wider.
"Whilst the OFT recognizes the immediate pressures of the economic climate, we believe it is important to
ensure that competition law, which is so important to the maintenance of a healthy economy and to ensuring
productivity, is not breached. We cannot comment on contact with individual companies."
The Government's pre-Christmas VAT cut was designed to bolster consumer spending in the lead up to Christmas
amid tough trading conditions on the UK high street.
A Model wears Ego Apparel at
Lingerie Fashion Show. Photo by ATI
November Retailers' Sales
Results in November were negatively impacted by having
one less week of holiday shopping compared with November 2007 along with the continuing slump in
consumer spending in the US.
Abercrombie & Fitch posted net sales of $267.3m for the four-week period, a 24% slump from last
year's sales of $352.3m. Same-store sales decreased 28%.
American Apparel reported a sales rise of 6% for the month of November over the year ago period.
Same-store sales soared 42%.
American Eagle Outfitters, total sales for November dropped 5% to $272.8m. Same-store
sales fell 11% for the month, compared to flat comps for the same period last year.
The Bon-Ton Stores said its same-store sales were down 16.0% compared with the
prior year period. Total sales decreased 15.5% compared with November 2007.
The Buckle posted same-store sales up 15.0%. Net sales for the four-week month to November
21, increased 21.6% to $72.2m from a year ago.
Cache said its same-store sales decreased 18% in November, with total net sales down
18% to $18.3m compared to the same period last year.
The Cato Corporation reported sales for the four weeks of November 2008 of
$60.6m, an increase of 4% over the same four week period last year. Comparable store sales for the month
Chico’s FAS reported that net sales for the four-week period were down 11.3%
to $118.5m from $133.6m last year. Same-store sales decreased 15.4%.
Dillard's announced sales for the four weeks ended November 29, of $505.75m, a
decrease of 10% compared to the prior year period. Same-store sales fell 9%.
Gap Inc reported a 10% drop in net sales for the four-week period to $1.39bn . The
company's same-store sales for November were down 10% compared with flat same-store sales in the same month
JC Penney Company's same-store sales dropped 11.9% for the four weeks and total company sales in
November fell 11.5%, both compared with November last year.
Kohl's Corporation has reported total sales down 13.7% for the four-week month ended
December 1. On a same-store basis, sales decreased 17.5%.
Limited Brands reported a same-store sales decrease of 12% for the four weeks of November.
The company's net sales fell 12% to $755.6m, down from $858.7m last year.
Macy's reported total sales of $2.327bn for the four weeks, a decrease of 14.1%
compared to the same month last year. On a same-store basis, sales were down 13.3% in November.
Mothers Work saw November net sales down 5.3% to $44.0m. Its 0.6% increase in
same-store sales for the month was in line with the company's guidance range.
Nordstrom posted sales of $707m for November, a decrease of 12.1% compared with
the same month last year. Same-store sales were down 15.9%.
Pacific Sunwear of California said total PacSun sales for fiscal November were
$101.0m, a decrease of 8%. PacSun same-store sales dropped 10%.
Ross Stores' sales were $568m, a 4% increase over November last year. Same-store sales for the four weeks
Saks Incorporated announced that owned sales totaled $332.9m for November 2008, a 4.2%
decrease on last year. Same-store sales decreased 5.2% for the month.
Stage Stores posted a 4.8% drop in its total sales for the four week November period, down to
$124.4m from $130.7m in the prior year. Same-store sales fell 8% versus an increase of 3.6% last year.
Stein Mart saw total sales drop 15.3% during November to $118.8m. The company's same-store
sales fell 14.2% during the month.
Target Corporation saw its net retail sales for the four weeks ended November
29, drop 6.1% to $5,605m. November same-store sales declined 10.4%.
The TJX Companies said November 2008 sales were $1.6bn, a 9% decrease from the four-week
period in 2007. Same-store sales were down 6% compared to last year.
Wal-Mart reported November sales of $32.213bn, up 1.6%, as same-store sales at its
US stores rose 3.4%.
The Wet Seal saw total sales fall 13.1% to $46m, compared to last year, as its
same-store sales dropped 13.9%.
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