Cut and Sew Apparel Manufacturing (except Contractors) — U.S. Industry Primer

NAICS 2022 code 315250. NAICS = North American Industry Classification System, the standard code set U.S. statistical agencies use to define industries.

---

1. Overview

This is the business of making finished clothing from purchased fabric — cutting, sewing, and selling ready-to-wear garments — done by firms that own the goods they produce, as opposed to job-shop contractors who merely sew for others. In plain terms, it is the domestic clothing factory (and the "design-and-arrange" clothing company behind it).

Here is the tension every investor should understand up front. The clothing market Americans buy from is roughly $362–366 billion at retail [1], but only about 2.5% of that clothing is actually made in the United States — roughly 97.5% is imported [2]. The United States imported $79.3 billion of apparel in 2023, mostly from Asia: China supplied $16.9 billion (about 21%), China and Vietnam together supplied just under 40%, and Bangladesh, Cambodia, India, Indonesia, and Pakistan collectively supplied $21.4 billion (27%) [3]. As a result, the measured U.S. manufacturing industry is small and shrinking: about $5.5 billion in annual receipts, ~24,900 workers, and ~1,300 plants [4][5]. The famous "apparel companies" a public-market investor knows — Ralph Lauren, Levi's, PVH, VF — are mostly brand marketers whose garments are sewn offshore, so their multi-billion-dollar revenues sit largely outside this domestic-manufacturing footprint. Understanding that gap is the whole point of this primer.

Why an investor cares. Two very different opportunities hide under one label. (a) A large, liquid set of public branded-apparel companies that design, source, and market clothing (and technically qualify here as "jobbers") but manufacture abroad — these are consumer-discretionary equities driven by brand strength, fashion, and margins. (b) A tiny, mostly-private world of actual U.S. sewing operations — micro-factories, uniform and defense suppliers, and "Made in USA" niche brands — where the investment case is speed, reshoring, and specialty contracts, not scale.

Public vs. private ways in. Public routes are plentiful but almost entirely brand/marketing plays (see Section 4). Pure domestic manufacturing is overwhelmingly private and small — family firms, contract shops, and venture-backed "Made in USA" brands — so getting exposure to the physical factory base usually means private equity, direct ownership, or supplier relationships rather than a stock ticker.

---

2. What it is & how it's structured

Scope. NAICS 315250 covers establishments that make cut-and-sew apparel from purchased fabric and own the product. It deliberately includes jobbers — firms that perform the entrepreneurial functions of apparel manufacture (buying raw materials, designing, preparing samples, arranging for the garments to be made, and marketing the finished apparel) even if they hire outside shops to do the sewing [6]. This is why a design-and-market clothing company can fall inside a "manufacturing" code without running its own sewing floor.

2022 NAICS reclassification (important for historical comparisons). Beginning with the 2022 NAICS revision, 315250 consolidates three former industries: men's and boys' apparel (315220), women's/girls'/infants' apparel (315240), and other cut-and-sew apparel (315280). The 2022 Economic Census bridge reports 416 employer firms and 442 establishments in former 315220, 738 firms and 742 establishments in 315240, and 526 firms and 529 establishments in 315280 — a combined 1,680 employer firms and 1,713 establishments mapped into the new code [7]. Any historical chart comparing the new 315250 only with one predecessor will be misleading.

What it EXCLUDES (name the neighbors). This code is one slice of the broader Apparel Manufacturing subsector (NAICS 315) [8]. Adjacent codes an investor should not confuse it with:

• 315210 — Cut and Sew Apparel Contractors: shops that cut/sew fabric owned by others for a fee. This is the excluded "contractor" half of the business [6].
• 315120 — Apparel Knitting Mills: firms that first knit the fabric, then make the garment.
• 315990 — Apparel Accessories and Other Apparel Manufacturing: belts, gloves, hats, and the like.
• Upstream: 313 Textile Mills / 314 Textile Product Mills (the fabric and made-up textile goods).
• Downstream distribution: merchant wholesalers (NAICS 424320/424330) and clothing retailers (NAICS 4581) — where most branded companies' U.S. establishments actually get classified, because their U.S. activity is design, wholesaling, and headquarters management, not sewing.

That last point is essential: a brand's offshore factories are counted in the host country's statistics, and its U.S. offices are often coded as wholesale or management — so its business is largely invisible in this line's U.S. numbers.

Ownership mix. Extremely fragmented and overwhelmingly small and private. The Census counts about 1,678 firms operating ~1,336 establishments [5][9] — i.e., most firms are single-location. The four largest firms hold just 13.2% of industry revenue (CR4), the top eight 19.8%, the top twenty 33.1%, and even the top fifty only 52.1% [9]. The Herfindahl-Hirschman Index (HHI, a standard 0–10,000 concentration gauge where higher means more concentrated) is a rock-bottom 84.3 [9] — one of the most fragmented manufacturing industries you will find. Nationally, over three-quarters of U.S.-based apparel makers have fewer than 10 employees [2].

---

3. How big it is

Our federal figures for NAICS 315250 (the U.S. domestic footprint only):

That implies average pay of roughly $46,000 per worker ($1.15B ÷ 24,878) [5] and revenue of about $3.3 million per establishment [5][9]. The U.S. Small Business Administration (SBA) sets the "small" cutoff at 750 employees [10] — meaning essentially every firm in this industry counts as a small business.

The undercount / context caveat (important). These manufacturing statistics capture only clothing physically produced in the U.S. They do not represent the size of the American clothing business. The U.S. apparel market is ~$362–366 billion at retail [1], and ~97.5% of it is imported [2]. The multi-billion-dollar revenues of the branded companies in Section 4 mostly flow through offshore production and U.S. wholesale/retail channels, so they are not inside this $5.5 billion manufacturing measure. Read the federal number as "the surviving domestic sewing base," not "the size of the industry an equity investor trades."

The domestic base is also still shrinking. U.S. apparel manufacturing output fell about 17% in 2025 by one industry index [11], and apparel has been among the fastest-declining U.S. factory-employment categories for two decades [12]. BLS projects apparel-manufacturing employment (broader NAICS 315) to decline from 84,500 in 2024 to 58,800 in 2034 — a loss of 25,700 jobs, or 30.4% [13]. Reshoring has been talked about far more than done: in a 2025 survey, three-quarters of brands pulled sourcing out of China, but they moved it to other low-cost Asian countries — only about 20% even considered U.S. manufacturing [11].

---

4. The investable universe

There is essentially no large, pure-play, publicly traded U.S. apparel manufacturer. The public names below qualify as "jobbers" under this code — they design, source, and market clothing — but they manufacture predominantly offshore, so treat them as branded consumer-discretionary equities, not domestic factory exposure. Figures are approximate recent annual revenue for scale.

Recent structural events matter for the map: HanesBrands was absorbed by Gildan (deal closed Dec 1, 2025) [20], and Delta Apparel filed Chapter 11 bankruptcy in mid-2024, was delisted, and sold its Salt Life brand for ~$38.7 million [27] — both illustrating how hard the economics have gotten even for larger, partly-domestic operators.

Uniform-service companies (indirect exposure). Investors seeking exposure closer to domestic manufacturing may consider uniform-rental and workwear-service companies, though their economics are primarily recurring services rather than merchant apparel sales. Cintas (CTAS) operates five manufacturing facilities for standard uniform requirements, but most of its economics come from rental, laundering, delivery, and facility services [28]. UniFirst (UNF) reported manufacturing approximately 62% of the garments it placed in service during fiscal 2025, but it too is primarily a recurring uniform-service company rather than a merchant apparel factory [29].

Major private / other owners (the actual domestic makers). The genuinely U.S.-manufacturing side is largely private: venture- and founder-owned "Made in USA" brands such as American Giant (U.S.-made basics, direct-to-consumer) [30] and Los Angeles Apparel; the Los Angeles garment cluster (~45,000 garment workers, mostly in small contract shops) [31]; and defense/uniform suppliers that produce domestically to meet federal sourcing rules (Section 7). For most investors, exposure to this segment means private equity, direct ownership, or being a customer/supplier — not a stock purchase.

---

5. How the money works

Two distinct economic engines sit under this code, and they earn money in opposite ways.

(a) The domestic cut-and-sew maker. Revenue is wholesale price per garment; the core cost is CMT — cut, make, trim (factory labor plus overhead per unit) [32]. A garment's cost builds up as: BOM (bill of materials — every fabric and trim item, where fabric alone is ~35–50% of factory cost for basics) → CMT labor → FOB (free-on-board factory price) → landed cost [32][33]. Because U.S. sewing wages are a large multiple of Asian wages, domestic makers generally cannot win on price. They make money instead on:

• Speed and replenishment — weeks not months, enabling fast fashion restocks and lower markdowns;
• Small-batch / low minimums — short runs uneconomic to import;
• "Made in USA" premium — a price the consumer will pay for the label;
• Compliant contracts — uniform and military work that must be domestic (Section 7).

Making-stage gross margins are thin and labor-sensitive; utilization (keeping sewing lines full) and input costs (cotton, synthetics tied to oil, and now tariffs on imported inputs) drive profit. USDA's July 2026 outlook forecasts world cotton production of 117.3 million bales against mill use of 122.0 million bales, with ending stocks down 6% — indicating prospective fiber-market tightness, though manufacturers often buy converted fabric under negotiated contracts rather than raw cotton [34]. It is a classic capacity-utilization, tight-margin manufacturing business.

(b) The branded jobber (the public names). These firms capture value in brand, design, and IP, and outsource the sewing. Healthy branded-apparel economics run roughly 60–70% gross margin at retail and ~40–50% at wholesale [33][35], with the difference between that and the ~15–30% markup of landed cost over FOB [32] flowing to marketing, design, distribution, and profit. For illustration, Kontoor Brands' 2024 gross margin was 44.5% and consolidated operating margin was 13.1%; management attributed the gross-margin improvement chiefly to lower product costs and channel/product mix [23]. Their levers: brand pricing power, mix (direct-to-consumer, or DTC, carries higher gross margin but higher fulfillment and returns cost), inventory discipline (markdowns destroy margin), and sourcing cost (duties, freight, factory prices). For these companies the swing variables are demand, inventory/markdown risk, and — acutely in 2025 — tariffs on their imported goods.

---

6. What drives demand

• Consumer discretionary spending. Clothing is a cyclical, deferrable purchase. Sales track disposable income, employment, and confidence; downturns hit apparel early and hard, and inventories whipsaw.
• Fashion cycles and seasonality. Trend shifts, weather, and holiday/back-to-school peaks drive volume and, critically, markdown risk.
• Price and the import gap. With ~97.5% of clothing imported [2], demand for domestic output specifically is a niche within the niche — created by speed, small runs, sourcing risk, and "Made in USA" preference rather than by overall clothing demand. U.S. apparel imports totaled $79.3 billion in 2023, with China and Vietnam together supplying just under 40% and Bangladesh, Cambodia, India, Indonesia, and Pakistan collectively supplying 27% [3].
• Trade policy and tariffs. The most powerful near-term swing factor. Average U.S. apparel-import tariffs jumped from ~14.7% in January 2025 to ~35.1% by December 2025 [11] — the highest in decades. Higher import costs are the single biggest potential tailwind for domestic makers (and headwind for import-reliant brands), though so far they have shifted sourcing between countries more than back home [11].
• Institutional / mandated demand. Federal purchasing (military uniforms, government workwear) provides a durable, domestic-only demand floor (Section 7).

---

7. Regulation

Apparel is lightly capital-regulated but carries meaningful labeling, safety, labor, and trade rules:

• FTC labeling (Federal Trade Commission). The Textile Fiber Products Identification Act and its Textile Fiber Rule require labels stating fiber content by weight, the manufacturer/marketer identity, and country of origin; the Care Labeling Rule requires cleaning instructions [36][37]. These apply to essentially all garments sold in the U.S. Origin claims are especially risky for firms combining domestic cutting or sewing with imported fabric and trims.
• Product safety (CPSC). The Consumer Product Safety Commission enforces the Flammable Fabrics Act — general clothing flammability standards (16 CFR Part 1610, prohibiting the most dangerously flammable Class 3 textiles) and stricter children's-sleepwear standards (Parts 1615/1616) [36][38]. Children's apparel additionally triggers CPSIA (Consumer Product Safety Improvement Act) testing and tracking requirements.
• Forced-labor / import rules (UFLPA). The Uyghur Forced Labor Prevention Act creates a rebuttable presumption that goods produced wholly or partly in the Xinjiang Uyghur Autonomous Region (XUAR), or by listed entities, are barred from U.S. entry, with no de-minimis exception to the ban itself. Apparel and cotton are designated high-priority enforcement sectors for U.S. Customs and Border Protection (CBP) [39][40]. This raises compliance cost and supply-chain-tracing burden for importers — and is a modest structural advantage for verifiably domestic producers.
• Domestic-sourcing mandates (Berry Amendment). For most Department of Defense (DoD) clothing purchases, the Berry Amendment requires that every textile step — fabric, thread, buttons, zippers — be U.S.-sourced and U.S.-made [41][42]. Defense Logistics Agency data show fiscal-2024 obligations of $101 million under NAICS 315250, compared with $624 million under the contractor code 315210 [43] — illustrating that much defense sewing flows through the contractor channel, but both codes sustain a domestic factory base that would otherwise struggle to compete. "Berry-compliant" capability is a genuine moat for the makers that have it.
• Labor law (federal and state). Federal law requires at least $7.25 per hour and overtime at 1.5× the regular rate after 40 hours, including for piece-rate workers [44]. California's SB 62 (Garment Worker Protection Act, 2022) banned piece-rate pay for garment workers, mandates hourly minimum wage, and — importantly — extends joint liability for wage violations up the chain to brands and contractors [45][46]. This raised costs and legal exposure in the largest U.S. garment cluster (Los Angeles) and is a template other states may follow.

---

8. Competitive dynamics & consolidation

At the making stage, competition is brutal and global. Domestic shops compete less with each other than with imports; the binding constraint is a labor-cost gap that scale cannot close. That is why the industry is so fragmented (CR4 just 13.2%, HHI 84.3) [9] and why headcount and output keep falling [11][12]. Survivors specialize — defense/uniform, technical/protective wear, fast-turn replenishment, or premium "Made in USA" — rather than chase commodity volume. Western Hemisphere production frequently costs more than Asian sourcing but provides shorter lead times, flexibility, and better U.S. inventory management; location decisions consider raw-material origin, tariffs, product cost, complexity, and the ability to respond to upside demand [23].

At the brand stage, consolidation is the story. Value has migrated from factories to brands and platforms, and the branded owners keep buying scale: Gildan's December 2025 acquisition of HanesBrands created a combined low-cost, vertically integrated basics leader targeting ~$200 million in cost synergies [20]. At the same time, weaker mixed operators fail — Delta Apparel's 2024 bankruptcy and delisting [27] is the cautionary case. Expect continued bifurcation: bigger, sourcing-efficient brand platforms on top; a thinning tail of small domestic manufacturers below; and tariffs, forced-labor rules, and defense contracts as the main forces that can slow (not reverse) the domestic decline.

---

9. Risks

• Structural import competition. The core, long-run risk to domestic makers: ~97.5% import penetration [2] and a persistent labor-cost disadvantage that keeps shrinking the base [11][12].
• Cyclicality and inventory/markdown risk. Discretionary demand is volatile; overbought inventory forces margin-destroying markdowns.
• Tariff / trade-policy whiplash. Tariffs are now the dominant variable, and they cut both ways — a tailwind for domestic producers, a direct margin hit for import-reliant brands. Policy can change fast [11]. Higher duties on finished garments may improve domestic producers' relative position, but tariffs on imported fabric, yarn, trims, or machinery can raise their own costs.
• Input-cost volatility. Cotton and oil-linked synthetic prices, plus freight, move factory costs directly [32][33]. USDA projects tightening cotton supply with ending stocks down 6% [34].
• Compliance and legal exposure. UFLPA detentions, CPSIA/flammability liability, and SB-62-style wage-liability laws raise cost and risk, especially for the import supply chain [39][45].
• Small-firm fragility. With most firms tiny and thinly capitalized [2][9], the domestic base is vulnerable to demand shocks, credit tightening, and key-customer loss — bankruptcies like Delta Apparel's show even larger players are exposed [27].
• Fashion / brand risk (for the public names). Brand relevance can fade quickly; a jobber's value is its label, and labels are perishable.
• Labor constraints. Sewing remains skill-intensive, and the long contraction in domestic apparel manufacturing has reduced the available workforce and supplier ecosystem.

---

10. How to invest & the outlook

Public routes. The liquid, practical way in is the branded-apparel equities in Section 4 (VFC, PVH, RL, LEVI, GIL, COLM, KTB, CRI, OXM, GES, GIII). Judge these as consumer-discretionary brand businesses — brand strength, gross margin, inventory discipline, DTC mix, and sourcing/tariff exposure — not as domestic factory bets, because their goods are mostly made offshore. Uniform-service companies (CTAS, UNF) offer somewhat closer manufacturing exposure, but their economics are primarily recurring rental and service revenue [28][29]. Investors specifically wanting tariff-resilient, domestically produced exposure have very thin public choices (e.g., micro-cap Digital Brands Group's Los Angeles production [26]); broad apparel or consumer-discretionary funds are the diversified alternative.

Private routes. Real domestic-manufacturing exposure is a private-market and operating play: acquiring or backing contract sewing shops and "Made in USA" brands, uniform/workwear and Berry-compliant defense suppliers (a protected, domestic-only demand pool [41][43]), or technical/protective niches. The investment thesis rests on speed-to-market, small-batch flexibility, compliance moats, and any durable "Made in USA" or tariff-driven reshoring premium — not on out-competing imports on price. Private diligence must first determine whether the target is genuinely 315250 (owns the product) or a fee-for-service 315210 contractor (sews others' material). It should then test customer concentration, backlog quality, fabric commitments, inventory aging, price-pass-through terms, plant utilization, workforce age and skill, subcontractor compliance, origin claims, government-contract dependence, and the capital required to automate cutting, planning, and material flow.

Near-term drivers (forward-looking). (1) Tariffs are the swing factor: sustained high import duties [11] would, over time, improve domestic makers' relative economics and pressure import-reliant brands — but the 2025 evidence is that sourcing shifts between countries far more readily than it returns home [11], so any reshoring benefit is likely to be gradual and selective rather than transformational. (2) Forced-labor enforcement (UFLPA) adds cost and tracing burden to imports and modestly favors verifiable domestic supply [39]. (3) Consolidation continues at the brand tier [20], with a thinning tail of small manufacturers below. (4) Consumer demand and inventory cycles will dominate the branded equities' quarterly results. (5) Secular employment decline: BLS projects a 30% drop in apparel-manufacturing jobs by 2034 [13]. Net judgment: the domestic manufacturing base is likely to stay small and specialized, defended by policy and niche demand rather than restored to scale; the investable action remains overwhelmingly on the branded, import-sourced side of the business.

---

Sources

1. Statista, "Apparel market in the U.S. — statistics & facts" (2025). https://www.statista.com/topics/965/apparel-market-in-the-us/
2. Kearney / industry analysis via search summary; AllAmerican.org, "State of American Clothing Manufacturing Report" (2025), reporting ~2.5% domestic / ~97.5% imported and firm-size distribution. https://allamerican.org/research/clothing-manufacturing-report/
3. U.S. International Trade Commission, "U.S. Imports for Consumption of Textiles and Apparel" (2023). https://www.usitc.gov/sites/default/files/publications/332/pub5543_0.pdf
4. U.S. Census Bureau, 2022 Economic Census & County Business Patterns, NAICS 315250 (aggregate scale). https://www.census.gov/programs-surveys/economic-census.html
5. U.S. Census Bureau, County Business Patterns 2023, NAICS 315250 (establishments 1,336; employment 24,878; annual payroll $1,151,585k; Q1 payroll $274,071k). https://www.census.gov/programs-surveys/cbp.html
6. U.S. Census Bureau, 2022 NAICS Definition, 315250 Cut and Sew Apparel Manufacturing (except Contractors); and 315210 Cut and Sew Apparel Contractors (2022). https://www.census.gov/naics/?chart=2022&details=315250&input=315250
7. U.S. Census Bureau, 2022 Economic Census Bridge Table, NAICS 315250 industry consolidation. https://data.census.gov/table/ECNBRIDGE22022.EC2200BRIDGE2?q=Economic+Census
8. U.S. Bureau of Labor Statistics, "Industries at a Glance: Apparel Manufacturing, NAICS 315" (2025). https://www.bls.gov/iag/tgs/iag315.htm
9. U.S. Census Bureau, 2022 Economic Census, Concentration statistics, NAICS 315250 (receipts $5,480,617k; 1,678 firms; CR4 13.2%, CR8 19.8%, CR20 33.1%, CR50 52.1%; HHI 84.3). https://www.census.gov/programs-surveys/economic-census.html
10. U.S. Small Business Administration, Table of Small Business Size Standards, NAICS 315250 (≤750 employees) (2023). https://www.sba.gov/document/support-table-size-standards
11. WWD / Sourcing Journal, "US Apparel Manufacturing Fell 17% in 2025" (Kearney Reshoring Index; tariff rise 14.7%→35.1%) (2026). https://wwd.com/sourcing-journal/trade/kearney-reshoring-index-usa-domestic-apparel-manufacturing-1238945612/
12. Sheng Lu / U.S. Fashion Industry Association, "The State of U.S. Textile and Apparel Manufacturing, Employment, and Trade" (2025). https://www.usfashionindustry.com/news/fashion-intel-analysis/the-state-of-u-s-textile-and-apparel-manufacturing-employment-and-trade
13. U.S. Bureau of Labor Statistics, "Industries with the fastest projected employment declines, 2024–2034" (NAICS 315: 84,500→58,800, -30.4%). https://www.bls.gov/emp/tables/industries-fast-decline-employment.htm
14. Statista / companiesmarketcap, VF Corporation total revenue (~$9.5B, FY2025). https://companiesmarketcap.com/vf-corp/revenue/
15. VF Corporation, Form 10-K FY2025 (sourcing from ~273 facilities in ~30 countries, ~260M units). https://www.sec.gov/Archives/edgar/data/103379/000010337925000023/vfc-20250329.htm
16. PVH Corp., 2025 Annual Report (10-K), FY2025 revenue ~$9.0B. https://www.pvh.com/news/press-releases/pvh-corp-reports-2025-fourth-quarter-revenue-and-earnings-above-guidance-provides-2026-outlook
17. Ralph Lauren Corporation, Form 10-K FY2025 (revenue $7.1B, +7%). https://www.sec.gov/Archives/edgar/data/1037038/000103703825000011/rl-20250329.htm
18. Levi Strauss & Co., FY2025 revenue $6.282B (stockanalysis.com / company reporting). https://stockanalysis.com/stocks/levi/revenue/
19. Levi Strauss & Co., Form 10-K FY2024 (sources nearly all products through independent contract manufacturers). https://www.sec.gov/Archives/edgar/data/94845/000009484525000005/lvis-20241201.htm
20. GlobeNewswire / Gildan Activewear, "Gildan Completes the Acquisition of HanesBrands" (Dec 1, 2025). https://www.globenewswire.com/news-release/2025/12/01/3197119/0/en/Gildan-Completes-the-Acquisition-of-HanesBrands.html
21. Carter's, Inc., Form 8-K FY2025 (net sales outlook ~$2.78–2.86B). https://www.sec.gov/Archives/edgar/data/1060822/000106082225000029/ex991cri-q42024.htm
22. Kontoor Brands, revenue ~$2.6B (2024) (Wikipedia / company reporting). https://en.wikipedia.org/wiki/Kontoor_Brands
23. Kontoor Brands, Form 10-K FY2024 (~30% internal manufacturing, ~70% from ~210 contract factories across 19 countries, 7 Mexico facilities; 44.5% gross margin, 13.1% operating margin). https://www.sec.gov/Archives/edgar/data/1760965/000176096525000011/ktb-20241228.htm
24. Oxford Industries, Form 8-K FY2025 (Q1 net sales $393M). https://www.sec.gov/Archives/edgar/data/75288/000007528825000077/oxm-05032025xexx991.htm
25. G-III Apparel Group, Form 10-K FY2025 (gross margin 40.8%; 39.4% wholesale, 50.4% retail). https://www.sec.gov/Archives/edgar/data/821002/000155837025003540/giii-20250131x10k.htm
26. Digital Brands Group, Inc., Form S-1 FY2025 (>90% U.S.-made, Los Angeles). https://www.sec.gov/Archives/edgar/data/1668010/000149315225019083/forms-1.htm
27. ASI / PPAI, "Delta Apparel Files for Chapter 11 Bankruptcy" and Salt Life sale (~$38.74M to Iconix) (2024). https://www.ppai.org/media-hub/delta-apparel-files-for-chapter-11-bankruptcy-plans-to-sell-salt-life-brand/
28. Cintas Corporation, Form 10-K FY2025 (operates five manufacturing facilities for standard uniform requirements). https://www.sec.gov/Archives/edgar/data/723254/000072325425000017/ctas-20250531.htm
29. UniFirst Corporation, Form 10-K FY2025 (manufactured ~62% of garments placed in service). https://www.sec.gov/Archives/edgar/data/717954/000119312525256222/unf-20250830.htm
30. Wikipedia / CBS News, "American Giant" (U.S.-made direct-to-consumer apparel). https://en.wikipedia.org/wiki/American_Giant
31. LAist / LA Fashion District, Los Angeles garment workforce (~45,000 workers) (2022–2025). https://laist.com/news/garment-conditions
32. Uphance, "Garment Costing and Pricing for Apparel Brands: BOM, Landed Cost, Margin Targets" (CMT, FOB, landed cost 15–30% over FOB, fabric 35–50% of FOB). https://www.uphance.com/blog/garment-costing-pricing/
33. AIMS360, "How to calculate profit margin in the fashion industry?" (wholesale vs. retail margin structure). https://www.aims360.com/fashion-business-resources/how-to-calculate-profit-margin
34. USDA Economic Research Service, "Cotton and Wool Market Outlook" (July 2026; production 117.3M bales, mill use 122.0M, ending stocks 71.2M, down 6%). https://www.ers.usda.gov/topics/crops/cotton-and-wool/market-outlook
35. TrueProfit, "Apparel Profit Margin Benchmarks (Gross, Operating & Net)" (60–70% gross retail benchmark). https://trueprofit.io/blog/apparel-profit-margin
36. U.S. Federal Trade Commission, "Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts," Care Labeling Rule, and Flammable Fabrics Act references (16 CFR Parts 300/303/423, 1610, 1615/1616). https://www.ftc.gov/business-guidance/resources/threading-your-way-through-labeling-requirements-under-textile-wool-acts
37. U.S. Federal Trade Commission, "Apparel Labeling" guidance. https://www.ftc.gov/news-events/topics/tools-consumers/apparel-labeling
38. U.S. Consumer Product Safety Commission, "Clothing" FAQ (flammability standards, Class 3 prohibition). https://www.cpsc.gov/FAQ/Clothing
39. CSIS, "Assessing the Impact of the Uyghur Forced Labor Prevention Act After Three Years" (2025); DHS 2025 UFLPA Strategy Update. https://www.csis.org/analysis/assessing-impact-uyghur-forced-labor-prevention-act-after-three-years
40. U.S. Customs and Border Protection, "Uyghur Forced Labor Prevention Act" explanation. https://www.help.cbp.gov/s/article/Article1842
41. Congressional Research Service, "Domestic Preference Statutes: The Berry Amendment and the Kissell Amendment" (IF13001). https://www.congress.gov/crs-product/IF13001
42. DFARS 225.7002-1, Berry Amendment Restrictions. https://login.acquisition.gov/dfars/225.7002-1-restrictions.
43. Defense Logistics Agency, Clothing and Textiles Small Business Report FY2024 (NAICS 315250 obligations $101.0M; 315210 obligations $624.3M). https://www.dla.mil/Portals/104/Documents/SmallBusiness/DB%20Flyers/2025%20Flyers/CandT%20SB%20-%20V-11-14-2025.pdf
44. U.S. Department of Labor, Wage and Hour Division, "Garment Workers' Rights" (minimum wage and overtime requirements for piece-rate workers). https://www.dol.gov/agencies/whd/garment-workers-rights
45. California Department of Industrial Relations, "Garment Worker Protection Act (SB 62)" FAQ (piece-rate ban, hourly minimum wage, joint brand liability) (2022). https://www.dir.ca.gov/dlse/GarmentFAQs/
46. California Division of Labor Standards Enforcement, Enforcement Policies and Interpretations Manual. https://www.dir.ca.gov/dlse/DLSEManual/dlse_enfcmanual.pdf