Cut and Sew Apparel Contractors (U.S.) — Industry Primer (5-digit rollup)

NAICS 2022 code 31521. NAICS is the North American Industry Classification System, the standard the U.S. government uses to define industries. This page covers the five-digit industry 31521, which sits one level above the six-digit national industry 315210.

Short page — single-child pass-through. At this level 31521 is identical to its one and only child, 315210 (Cut and Sew Apparel Contractors). Everything in the five-digit industry is the six-digit industry; the two codes describe the same set of businesses and carry the same federal statistics. This page gives the rollup figures and the essentials, then points you to the full 315210 primer for the detail. For the complete story — how the money works, the investable names, regulation, risks, and outlook — read the 315210 primer.

1. Overview

Cut and sew apparel contractors are the sewing shops that turn a brand's cloth into finished garments for a fee. The defining feature is that they do not own the materials or the design — a fashion label, wholesaler, or uniform supplier hands them fabric and a pattern and pays them to cut and stitch it. The trade calls this CMT work — "cut, make, trim."[1][9] It is the domestic equivalent of the overseas garment factory, run as a job shop.

This is a small, shrinking, and extremely fragmented U.S. industry: roughly $2.0 billion in annual receipts and about 22,700 workers (federal figures, Section 3),[2][6] against a backdrop where only about 2.5% of the apparel bought in America is made in America — the United States imported $79.3 billion of apparel in 2023, mostly from Asia.[5][14] The decline is ongoing: the establishment count fell roughly 28% between 2017 and 2023, from 2,921 to 2,094 employer establishments.[6][15] For an investor, the practical point is that there is no publicly traded U.S. pure-play of scale — the industry matters as a private-market niche and as a barometer of reshoring and trade policy (Sections 4 and 10).

2. What's inside — and why this level equals its one child

The five-digit industry 31521 contains exactly one six-digit national industry:

Because there is only one child, 31521 and 315210 are the same thing — the U.S. statistical system simply carries the industry down one more digit without splitting it. There are no sibling industries to weigh against each other, no internal mix to analyze. The rollup figures below are the child's figures.

For context, the neighboring codes that are not part of 31521 (and that an investor should not confuse with it) include 315250 — Cut and Sew Apparel Manufacturing (except Contractors), the firms that buy their own fabric and market the clothing; 315120 — Apparel Knitting Mills; and 315990 — Apparel Accessories and Other Apparel Manufacturing. Owning the materials is the line that separates a contractor (315210/31521) from a manufacturer.[2] The child primer details these boundaries.

3. How big it is (rollup figures)

Because 31521 has a single child, its statistics are simply 315210's statistics. Federal ground-truth figures for this level:

What the numbers say: pay divided by headcount is about $36,700 per worker per year, well below the U.S. manufacturing average and reflecting entry-level, hand-intensive sewing;[6] and ~22,700 workers across ~2,094 establishments is only ~11 employees each, with average revenue per firm under $1 million and average assets of just $0.3 million per firm — a micro-scale, atomized industry.[2][6][16] California dominates, with roughly 1,332 establishments and 10,800 employees (about 64% of national establishments and 48% of employment), followed by New York, Dallas, and Miami.[17]

Undercount caveat — important here. County Business Patterns counts only employer establishments (businesses with at least one paid employee). Cut-and-sew is exactly the kind of industry where that misses a lot: home-based sewers, one-person contractors, and informal or unregistered shops — the same shadow segment behind the Los Angeles wage-theft cases. Private research firm IBISWorld's broader business count runs into the thousands more once non-employers are included.[4] So treat ~2,094 establishments as a floor on the number of operators, not a full census.

4. Investable universe — where the value sits

Since the level is a single child, all of the value sits in 315210, and the honest bottom line is: there is no clean public play. No sizable U.S.-listed company's main business is contract cut-and-sew inside the United States — the industry is too small, fragmented, and low-margin — and the one recent listed name with heavy domestic apparel exposure, Delta Apparel, filed Chapter 11 in 2024.[12]

Investors reach the industry two ways, both covered fully in the child primer:

• Indirect public exposure through vertically integrated apparel makers (Gildan, ticker GIL; Hanesbrands, ticker HBI) whose sewing is mostly offshore, and through adjacent uniform/workwear names (Cintas, ticker CTAS; UniFirst, ticker UNF; Superior Group of Companies, ticker SGC; Lakeland Industries, ticker LAKE). Each is a proxy, not the thing itself.
• Direct private ownership — buying or building a contract sewing shop, ideally in a defensible niche such as Berry-compliant defense sewing (firms such as ReadyOne Industries, Mills Manufacturing, Propper),[18] quick-turn direct-to-consumer (DTC) work, or tailored/technical garments; plus private-equity roll-ups in uniforms and workwear.[11][13] Fechheimer, which manufactures public-safety, postal, and military uniforms, is owned by Berkshire Hathaway — one of the few identifiable public-company ownership links to this space, though it is immaterial to the conglomerate.[19]

Buyer power is substantial. Major brands source globally and maintain no long-term manufacturing contracts, giving them enormous leverage. G-III Apparel sourced approximately 76% of its fiscal-2025 product from Vietnam, China, and Indonesia;[20] Levi Strauss sourced from manufacturers in approximately 32 countries in fiscal 2025.[21] Domestic contractors compete not only with neighboring shops but with a globally contestable supplier base.

See the 315210 primer, Section 4, for the full company-by-company table and caveats.

5. How the money works (in brief)

Contractors sell labor and machine time, priced per garment under CMT. The brand owns the fabric; the contractor bills a fee covering sewing labor, factory overhead, and a thin margin. The underlying math is cost-per-minute × minutes-per-garment, where minutes come from a garment's SMV (standard minute value — the industry's estimate of the sewing time a garment needs). Contractors typically add only a ~10–15% margin on the labor portion, so profit lives or dies on capacity utilization, labor efficiency, and shifting toward higher-value garments.[9][10] There is no franchising, recurring-revenue, or same-store-sales model — it behaves like a low-margin, high-cyclicality machine job shop. Full detail is in the child primer, Section 5.

6. Demand drivers (in brief)

The single biggest driver is where brands choose to make clothes — the offshore-versus-domestic sourcing decision, which has pulled most volume abroad for decades.[5][6] The domestic growth pockets are small-batch, on-demand, quick-turn "Made in USA" production for DTC and premium brands; reshoring/nearshoring momentum (best understood as portfolio tools — brands may use Asian factories for predictable high-volume programs while reserving domestic capacity for test runs or fast replenishment);[13][22] protected government demand under the Berry Amendment; and steadier uniform and workwear contracts.[11][13] All of it rides the broader fashion cycle and discretionary-spending macro. See the child primer, Section 6.

7. Regulation (in brief)

The defining regulatory force is labor and wage law. California's Garment Worker Protection Act (SB 62, effective 2022) made California the first state to ban piece-rate pay for garment work, require an hourly minimum wage, and make brands jointly liable for wage theft in their contractors' shops — with a $200-per-employee, per-pay-period penalty for piece-rate violations — raising the domestic cost floor.[7][8][23] The enforcement record is material: a Department of Labor survey of 50 Southern California garment contractors in 2022 found violations in 80% of cases and recovered more than $892,000 for 296 workers.[24]

On the demand side, the Berry Amendment (10 U.S.C. §4862) requires the U.S. Department of Defense to buy 100% U.S.-made clothing and textiles, reserving military-apparel orders for domestic shops.[11] Trade policy — the 2025 suspension and pending 2027 repeal of the duty-free "de minimis" exemption for sub-$800 parcels, plus agreements like USMCA and CAFTA-DR — sets the import backdrop.[3] Full treatment in the child primer, Section 7.

8. Consolidation

This is one of the most fragmented manufacturing industries in the United States, and it is fragmenting further rather than consolidating. The federal concentration data (identical to the child's, since the codes are the same) make the point:[2]

An HHI (a 0–10,000 concentration score; antitrust regulators treat anything under 1,500 as "unconcentrated") of ~80 is effectively atomized — no firm has pricing power, and it takes the 50 largest firms combined just to reach half the market.[2] What consolidation exists is concentrated in uniforms and workwear private-equity roll-ups, not the fashion-facing sewing base. The child primer, Section 8, expands on this.

9. Risks (in brief)

The risks are the child's risks: import competition is existential (overseas CMT is far cheaper);[5][6] margins are thin and fragile (a small move in wages, rent, or utilization flips a shop to a loss);[10] labor cost and skilled-sewer scarcity keep rising;[8][13] wage-theft liability now reaches up to brands and the 80% violation rate in recent DOL inspections underscores enforcement risk;[7][24] shops face customer concentration and cyclicality;[4] reshoring may disappoint because the mill-and-labor infrastructure takes years to rebuild;[13] and for investors, exposure is illiquid and private.[12] See the child primer, Section 9.

10. How to invest and outlook

Because 31521 is its one child, the investment case is 315210's: narrow and private. Public routes are indirect and imperfect — integrated apparel and uniform names give a partial read, but there is no pure-play domestic contractor to buy, and the last domestic-heavy listing went bankrupt.[12] The real exposure is direct private ownership of a well-run shop in a defensible niche (quick-turn DTC, tailored/technical, or Berry-compliant defense) or a uniform/workwear roll-up.[11][13]

The honest outlook: the domestic cut-and-sew contractor industry is small and secularly challenged, and nothing on the horizon restores its 20th-century scale — but the ground is shifting in its favor at the margin (tariffs on cheap imports, speed-and-flexibility demand, "Made in USA" preference, protected defense orders). For most investors, 31521/315210 is best understood as a barometer of reshoring and trade policy and as a private acquisition or founder opportunity, not a sector to own through a stock ticker.

→ For the complete primer — full investable-universe table, cost economics, regulatory detail, and forward-looking drivers — see 315210 — Cut and Sew Apparel Contractors.

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Sources

1. U.S. Census Bureau / NAICS Association. "NAICS Code 315210 — Cut and Sew Apparel Contractors (definition)." 2022. https://www.census.gov/naics/
2. U.S. Census Bureau. "2022 Economic Census — Concentration Ratios and Selected Statistics, NAICS 315210 (firms, receipts, CR4/CR8/CR20/CR50, HHI)." 2022. https://www.census.gov/programs-surveys/economic-census.html
3. Forbes / CNN Business. "Trump Suspends De Minimis Tariff Exemption for Goods Under $800 (Temu, Shein)." 2025. https://www.forbes.com/sites/zacharyfolk/2025/07/30/trump-suspends-de-minimis-tariff-exemption-for-goods-under-800/
4. IBISWorld. "Cut & Sew Apparel Contractors in the US — Industry Analysis." 2026. https://www.ibisworld.com/united-states/industry/cut-sew-apparel-contractors/339/
5. AllAmerican.org. "State of American Clothing Manufacturing Report." 2024. https://allamerican.org/research/clothing-manufacturing-report/
6. U.S. Census Bureau. "County Business Patterns 2023, NAICS 315210 (establishments, employment, payroll)." 2023. https://www.census.gov/programs-surveys/cbp.html
7. Remake / Fashion Revolution. "FAQ: The Garment Worker Protection Act (SB 62)." 2022. https://remake.world/stories/faq-the-garment-worker-protection-act-sb62/
8. Epstein Becker Green (Wage & Hour Blog) / National Law Review. "California Becomes First State to Ban Piece Rate Pay for Garment Workers." 2021. https://www.wagehourblog.com/california-becomes-first-state-to-ban-piece-rate-pay-for-garment-workers
9. Cosmo Sourcing. "CMT Explained: What Cut, Make, and Trim Mean When You're Sourcing Apparel." 2024. https://www.cosmosourcing.com/blog/what-does-cut-make-and-trim-cmt-mean
10. Jinfeng Apparel. "How to Cost a Garment for CMT (Cut, Make, and Trim)?" 2024. https://jinfengapparel.com/how-to-cost-a-garment-for-cmt-cut-make-and-trim/
11. U.S. Department of Defense, Office of the Under Secretary (Acquisition & Sustainment) / US Made Supply. "The Berry Amendment (10 U.S.C. §4862)." 2024. https://www.acq.osd.mil/asda/dpc/cp/ic/berry-amendment.html
12. Advertising Specialty Institute (ASI) / PPAI. "Delta Apparel Files Chapter 11 Bankruptcy; Assets Sold (Salt Life, Soffe)." 2024. https://members.asicentral.com/news/industry-news/july-2024/delta-apparel-s-stock-to-be-delisted-amid-bankruptcy/
13. Maker's Row / SEAMS / USMadeFinds. "Apparel & Garment Industry Trends in the USA — Reshoring, Small-Batch and On-Demand Manufacturing." 2025–2026. https://makersrow.com/blog/apparel-garment-industry-usa/
14. U.S. International Trade Commission. "Apparel: Textiles and Apparel Technical Guide." 2023. https://www.usitc.gov/keywords/textiles_and_apparel
15. U.S. Bureau of Labor Statistics / Census Bureau. "NAICS Revision Attachment — 2017 Benchmark Data for 315210." 2020. https://downloads.regulations.gov/USBC-2020-0004-0028/attachment_1.pdf
16. U.S. Small Business Administration. "Size Standards Analysis, NAICS 315210 (firm size, assets, concentration)." 2022. https://public-inspection.federalregister.gov/2022-08091.pdf
17. California Employment Development Department. "QCEW Industry Data, NAICS 315210, 2022." 2022. https://labormarketinfo.edd.ca.gov/qcew/CEW-Detail_NAICS.asp
18. ReadyOne Industries. "About — Military Apparel Manufacturing." 2025. https://www.readyone.org/
19. Berkshire Hathaway Inc. "2023 Form 10-K (Fechheimer ownership)." 2024. https://www.sec.gov/Archives/edgar/data/1067983/000095017024019719/brka-20231231.htm
20. G-III Apparel Group, Ltd. "Fiscal 2025 Form 10-K (sourcing, buyer power)." 2025. https://www.sec.gov/Archives/edgar/data/821002/000155837025003540/giii-20250131x10k.htm
21. Levi Strauss & Co. "Fiscal 2025 Form 10-K (sourcing diversification)." 2026. https://www.sec.gov/Archives/edgar/data/94845/000009484526000008/lvis-20251130.htm
22. International Trade Administration / SelectUSA. "Textiles Industry Overview — Reshoring and Nearshoring." 2025. https://www.trade.gov/selectusa-textiles-industry
23. California Department of Industrial Relations. "Garment Industry — SB 62 and Registration Requirements." 2022. https://www.dir.ca.gov/dlse/Garment/
24. U.S. Department of Labor. "DOL Recovers More Than $892,000 for 296 Garment Workers in Southern California; Beyond Yoga Enforcement Action." 2024. https://www.dol.gov/newsroom/releases/whd/whd20240103-1