CAFTA-DR Annex 3.25 Adds Faux Leather Fabric

CAFTA-DR Annex 3.25 now includes a narrowly specified faux leather fabric bonded to pile fabric in unrestricted quantities. Effective October 2, 2026, the commercial availability determination gives qualifying apparel and footwear producers another potential sourcing option while preserving preferential tariff treatment when all applicable requirements are met.

What the New Annex 3.25 Listing Changes

The Committee for the Implementation of Textile Agreements determined that the specified fabric is not available in commercial quantities in a timely manner within the CAFTA-DR countries. The fabric was therefore added to Annex 3.25, commonly called the CAFTA-DR short-supply list, in unrestricted quantities.

Commercial Availability and Non-Originating Inputs

CAFTA-DR textile and apparel rules generally require qualifying products to satisfy detailed origin criteria. Depending on the product, these requirements may address the origin of yarn, fabric, sewing thread, or other textile components. Annex 3.25 provides a targeted exception for designated materials that are not commercially available within the agreement’s territory under the prescribed conditions.

For producers, the new listing means that qualifying goods may generally incorporate the covered non-originating faux leather bonded fabric without losing CAFTA-DR eligibility solely because that fabric originated outside the CAFTA-DR region. The finished good must still meet every other applicable requirement, including classification, production, direct shipment, certification, and recordkeeping rules.

“Unrestricted quantities” does not make all faux leather fabrics eligible. It means the listing does not impose a stated quantitative ceiling on use of the fabric that satisfies the approved description. The technical specifications remain controlling. A visually similar fabric, a different fiber blend, or a construction outside the listed weight and width ranges may not qualify.

Importers and producers should therefore treat the listing as a precise sourcing provision rather than a broad exemption for bonded faux leather. Eligibility typically depends on matching the approved specifications and connecting that material to a finished good that independently qualifies for CAFTA-DR preference.

Technical Specifications Require Exact Product Matching

The approved material is a knit faux leather fabric bonded to a sherpa-style pile backing. The listing identifies HTS classifications 6001.10 and 6001.92.00, but tariff classification alone is not sufficient to establish that a fabric falls within Annex 3.25.

Covered Construction and Composition

The fabric specifications include the following characteristics:

• Fabric type: Knit faux leather bonded to a pile fabric
• Face fabric: 100% polyester knit made with 75-denier sea-island filament
• Backing: Sherpa knit pile containing 60% to 64% polyester and 36% to 40% acrylic
• Weight: 442 to 488 grams per square meter
• Width: 137 to 143 centimeters
• Bonding process: Moltopren heat process, also described as flame lamination
• Finished pile height: Approximately 4 to 7 millimeters on the sherpa back
• Identified HTS provisions: 6001.10 and 6001.92.00

Each characteristic can affect whether a shipment matches the commercial availability description. For example, a fabric with a polyurethane face, a backing outside the specified fiber percentages, or an adhesive-laminated construction rather than the specified heat process may fall outside the listing even if marketed under the same commercial name.

Trade compliance teams should maintain technical records that extend beyond supplier invoices. Useful support typically includes specification sheets, laboratory reports, fiber-content documentation, production records, purchase orders, and written confirmation of the lamination method. Fabric weight and width should be documented in the units used by the listing or converted through a controlled and reviewable method.

The HTS provisions should also be confirmed against the imported material’s actual construction. Classification and Annex 3.25 matching are related but distinct analyses: an HTS number does not replace a specification review, and a specification match does not eliminate the need for correct classification.

Compliance Implications for CAFTA-DR Supply Chains

The listing creates sourcing flexibility, but it also introduces a new validation requirement. Producers, importers, and customs brokers need a repeatable process for proving that the non-originating fabric used in a preferential shipment is the same material covered by Annex 3.25.

Building a Defensible Preference File

A defensible file generally begins at the bill-of-materials level. The manufacturer should identify the covered fabric as a distinct component, connect it to the relevant supplier and purchase lot, and preserve production records showing where it was consumed. If multiple bonded fabrics are used at the same facility, inventory controls should prevent eligible and noneligible materials from being treated interchangeably.

The finished article must then be tested under its applicable CAFTA-DR rule of origin. The short-supply designation typically resolves only the originating status of the listed fabric for purposes of the relevant commercial availability provision. Other fabrics, yarns, linings, sewing thread, elastics, or components may remain subject to separate origin requirements.

Importers should also coordinate the effective date with production and entry records. The addition applies beginning October 2, 2026. Preference claims involving earlier transactions require separate review and should not be assumed to qualify under the later determination.

For customs brokers, intake procedures should distinguish a general request for CAFTA-DR treatment from a claim relying on Annex 3.25. The latter warrants collection of the exact fabric description, HTS classification, composition, dimensions, weight, bonding process, pile height, manufacturing records, and supporting certification.

Post-entry reviews are equally important. A discrepancy between commercial descriptions and technical records can expose an importer to preference corrections, duty liability, and questions about reasonable care. Periodic reconciliation of purchase, production, export, and import data helps identify quantity or specification gaps before they become systemic.

Frequently Asked Questions

What Is CAFTA-DR Annex 3.25?

Annex 3.25 contains fabrics, yarns, and other textile inputs determined not to be available in commercial quantities in a timely manner within the CAFTA-DR region. Qualifying producers may generally use listed non-originating materials under the agreement’s commercial availability rules, provided the finished goods satisfy all other applicable origin and procedural requirements.

Does the Listing Cover Every Type of Faux Leather Fabric?

No. The listing is limited to the specified knit polyester faux leather face bonded to a polyester-acrylic sherpa pile backing. Fiber percentages, filament size, weight, width, lamination process, and pile height are material parts of the description. Similar appearance or commercial terminology does not establish eligibility.

What Does “Unrestricted Quantities” Mean?

It means Annex 3.25 does not impose a specific quantitative limit on use of material meeting the approved description. It does not remove the technical restrictions or automatically qualify every finished product containing the fabric. Producers still need to establish a specification match and compliance with the finished article’s CAFTA-DR rule.

Can an Importer Rely Only on the Supplier’s Certificate?

A supplier certificate may support the claim, but it is generally insufficient by itself when it lacks technical and production detail. Importers should retain specification sheets, fiber-content records, weight and width data, bonding-process confirmation, purchase documents, inventory records, and evidence connecting the fabric to the exported merchandise.

Which HTS Numbers Are Associated With the Fabric?

The listing identifies HTS 6001.10 and 6001.92.00. The correct classification depends on the fabric as imported, and neither number should be applied without reviewing its physical characteristics. Importers should confirm both the HTS classification and the full Annex 3.25 description before making a preference claim.

How Stable Software Can Help

Supporting Broker-Led Duty Recovery

CAFTA-DR preference management and duty recovery both depend on accurate, connected import data. When eligible preference was not claimed at entry, trade teams may need to assess available post-entry remedies; separately, unused or exported merchandise may create duty drawback opportunities depending on the facts.

DrawbackAI gives U.S. customs brokers duty drawback software they can white-label for importer clients and use to file under their own filer code. Stable Software charges a flat software license and never takes a percentage of the refund. Brokers seeking to expand their trade services can evaluate where drawback fits alongside origin reviews, entry corrections, and broader duty-optimization programs.

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