Apparel Accessories and Other Apparel Manufacturing (U.S., NAICS 315990)

1. Overview

This industry makes the small, finishing pieces of a wardrobe: hats and caps, gloves and mittens, belts, neckties and bow ties, plus a catch-all of other apparel items and trimmings.[1] It is the "everything else" bucket of U.S. apparel manufacturing — what is left after the big categories (shirts, pants, dresses, knitwear) are carved out.

For an investor, the single most important fact is a mismatch: Americans buy a lot of hats, gloves, belts, and ties, but very few are made in the United States. Domestic factories in this code generate only about $1.0–1.2 billion in shipments a year — and that figure has been declining, from $1.10 billion in 2022 to $961.5 million in 2025 by BLS's sectoral-output measure.[2][3] Employment has likewise contracted: the BLS all-worker measure (including self-employed and unpaid family workers) shows 17,000 jobs in 2022 falling to 14,800 in 2025.[4] Most accessories sold here are imported, and most of the well-known "accessory companies" are designers, licensors, and importers rather than domestic manufacturers.

Ways in differ sharply by investor type:

• Public-market investors have no clean, pure-play way to own this specific industry. Exposure comes indirectly through large, diversified apparel and fashion-accessory companies that design and market hats, belts, or ties but manufacture them overseas.
• Private investors are closer to the real action. The category's defining businesses — branded headwear makers, men's-accessory licensing platforms, "Made in USA" and military-spec glove shops, and industrial work-glove suppliers — are almost entirely privately held.

2. What it is and how it's structured

Scope. NAICS 315990 covers establishments that make apparel accessories and miscellaneous apparel not classified elsewhere. Typical products: belts, caps and hats (baseball caps, fur-felt hats, chauffeur caps), gloves and mittens (leather, fabric, fur, knitted), neckties, bow ties and ascots, plus waterproof aprons, handkerchiefs, bibs, and cut-and-sewn apparel findings and trimmings.[1] The code also includes jobbers — firms that buy raw materials, design and sample the product, contract out the actual sewing, and market the finished accessory. That "asset-light" model matters a lot here (see Section 5).[1][5]

What it excludes (adjacent NAICS codes an investor should not confuse with this one):

• 315120 – Apparel Knitting Mills (knit-then-make garments).[1]
• 315210 – Cut and Sew Apparel Contractors (cut/sew on materials owned by others).[1]
• 315250 – Cut and Sew Apparel Manufacturing (except Contractors) (shirts, pants, dresses, coats from purchased fabric).[1]
• Handbags, wallets, and personal leather goods sit in the leather-goods codes (NAICS 3161/3169), not here — a key point, because much of the "accessories" market cap on public exchanges is really handbags and small leather goods.
• Medical, surgical, sporting, and safety gloves are explicitly excluded and classified with medical or rubber/plastics products.[1]

Ownership mix. Domestically the industry is a long tail of small, private, often family-owned or employee-owned shops and custom makers, plus a handful of larger branded firms. The Economic Census counts about 650 employer firms operating roughly 729 establishments.[2][6] There is no publicly traded company whose core business is domestic apparel-accessory manufacturing.

3. How big it is

Federal statistics for the domestic manufacturing base (our ground-truth figures):

That $1.0–1.2 billion is small — and it understates the economic footprint of the category in three ways:

1. Imports dominate consumption. The federal number counts only what is manufactured in U.S. establishments. The vast majority of hats, gloves, belts, and ties Americans buy are imported, so the domestic-manufacturing figure captures a small slice of accessory spending.[9]
2. The biggest players aren't counted as manufacturers. Category leaders such as New Era (headwear) and Randa (men's accessories) design, license, and market at large scale but source production offshore, so much of their revenue does not show up in this manufacturing code.[10][11]
3. Tiny and individual operators fall through the cracks. Custom milliners, one-person glove and hat makers, and craft sellers are frequently nonemployer businesses excluded from the employer-firm counts above.

The SBA sets the small-business threshold at 600 employees[8] — far above the industry's average establishment (about 11 workers), a sign that federal policy treats essentially every domestic maker in this code as a small business.

4. The investable universe

There is no pure-play publicly traded U.S. apparel-accessory manufacturer. Public exposure is indirect, through diversified apparel and fashion-accessory companies; the category's defining brands are private.

Public companies with accessory exposure (all diversified; most manufacture offshore):

Note: handbag- and leather-goods-heavy names (Tapestry, Capri) are often lumped into "accessories," but their products mostly belong to the leather-goods codes, not NAICS 315990.

Major private / other owners (closer to the actual product category):

Takeaway: if you want direct exposure to making U.S. hats, gloves, belts, and ties, the ownership is private. ACON's investment in New Era is the clearest demonstrated institutional-private-equity route.[16] Public equities give you diversified apparel businesses with an accessory line, not a bet on this industry.

5. How the money works

This is a labor-intensive, thin-margin manufacturing business with modest fixed capital (sewing machines, cutting tables, presses), so the economics revolve around a few levers rather than a rate base or recurring fees.

Cost structure. BLS estimated labor's share of total production cost at 36.2% in 2022.[19] Recent cost indicators are unfavorable: the industry's labor-productivity index (2017 = 100) fell from 77.7 in 2022 to 73.2 in 2024, while unit labor costs rose from 124.1 to 139.1 over the same period.[20][21] The output-price deflator rose from 125.5 to 137.8, suggesting some price realization but not necessarily full cost pass-through.[22]

How owners actually make money — four playbooks:

1. Compete on speed and specialization, not price. Domestic makers cannot win on labor cost against Asian imports, so survivors sell small-batch runs, fast reorders, custom and private-label work, and quality — things importers with long lead times struggle to match. Premium and niche domestic cut-and-sew work can run gross margins in the mid-teens to mid-30s percent; commodity work runs far thinner.[23]
2. The jobber / licensing model (asset-light). Firms like Randa design the product, license a brand name, contract the sewing offshore, and capture the brand margin without owning factories.[11] Branded headwear (New Era) layers league and college licensing royalties on top — the highest-value, most defensible niche in the category.[10]
3. "Made in USA" and government premiums. A domestic label commands a price premium with some consumers, and the Berry Amendment requires the Department of Defense to buy 100%-U.S. textiles and clothing — including gloves and headwear — creating a protected, higher-margin channel for compliant makers.[18]
4. Industrial and work-glove volume. Work gloves ride steady demand from construction, manufacturing, and warehousing employment — less fashion-driven, more tied to the industrial economy.

Metrics that matter for this industry: gross margin and unit economics per item; capacity utilization (fixed costs spread over volume); input costs (cotton, wool, leather, synthetics) and the ability to pass them through in price; inventory turns and obsolescence (fashion items date quickly); and, for the branded players, licensing royalty rates and license renewals. Cyclicality is real — these are discretionary consumer goods, so demand softens in downturns. U.S. households averaged $2,001 of apparel-and-services expenditure in 2024, down 2.0% from 2023, though that broader measure extends well beyond accessories manufacturing.[24]

6. What drives demand

• Fashion and style cycles. Ties, hats, and belts move in and out of favor; the multi-year decline in men's necktie wearing is a structural headwind, while headwear as streetwear has been a tailwind.
• Licensed sports and entertainment. Team caps and fan headwear are a large, brandable, repeat-purchase driver — the healthiest corner of the category. New Era's league-wide NHL agreement made it a licensee across the NHL's 32 clubs and all five major North American team-sport leagues.[10][25]
• Seasonality and weather. Cold-weather gloves and winter hats concentrate demand in fall/winter; mild winters hurt.
• Corporate, promotional, team, and uniform demand. Branded caps and custom accessories for companies, events, schools, and teams.
• The industrial economy. Work-glove demand tracks construction and manufacturing activity and safety requirements.
• Discretionary income and consumer confidence. Accessories are add-on, impulse-friendly purchases sensitive to the spending cycle.
• Reshoring and "Made in USA" sentiment, plus military procurement under Berry rules, support the domestic niche specifically.[18][23]
• De minimis suspension. Duty-free treatment for shipments valued at or below $800 was suspended globally effective August 29, 2025, raising the compliance and landed cost of direct foreign shipments and potentially helping domestic and conventional wholesale channels.[26]

7. Regulation

Accessories carry the same consumer-product and trade obligations as garments:

• Consumer Product Safety Commission (CPSC). The Flammable Fabrics Act (16 CFR 1610) sets clothing-textile flammability standards, though most hats and gloves shorter than 14 inches are excluded; children's sleepwear has stricter rules (16 CFR 1615/1616); children's outerwear faces drawstring limits; and children's products require third-party testing and permanent tracking labels.[27][28]
• Federal Trade Commission (FTC). The Textile Fiber Products Identification Act requires fiber-content, country-of-origin, and manufacturer-identity (RN) labeling.[27] The Care Labeling Rule's permanent-label requirements exempt or exclude hats, gloves, belts, suspenders, and neckties.[29]
• Customs and Border Protection (CBP). Imports face tariff classification by HTS code, country-of-origin marking, and — increasingly — forced-labor enforcement (below). CBP reported $124.9 billion of U.S. textile and apparel imports in fiscal 2024 and an average duty rate of 16% across that broader universe.[30]
• Berry Amendment (10 U.S.C. 4862). DoD-purchased clothing and textiles, including gloves and headwear, must be 100% U.S.-made from fiber forward — a compliance burden and a competitive moat for domestic makers.[18]
• California textile EPR. California's textile extended-producer-responsibility program covers clothing and accessories; Landbell USA was approved as the producer responsibility organization on February 27, 2026, with covered producers required to join by July 1, 2026. Regulations take effect no earlier than July 2028, with full implementation scheduled for 2031. Fees, reporting, and product-accounting requirements will fall on brands and other statutory "producers."[31]

8. Competitive dynamics and consolidation

Domestically the industry is fragmented and unconcentrated. The four largest firms account for just 19.1% of receipts, the top eight for 27.6%, and the top 50 for 63.1%; the Herfindahl-Hirschman Index (HHI) is 151.4 — far below the ~1,500 level antitrust regulators treat as "moderately concentrated."[6] In plain terms: a long tail of small shops, no dominant domestic manufacturer.

The concentration that does exist sits at the brand and license layer, not the factory. A few players own specific niches — New Era in licensed caps, Randa in men's accessories — and consolidation happens through brand roll-ups and licensing deals rather than factory mergers. New Era's 2024 acquisition of '47, combining two major sports-headwear brands into a roughly $2-billion company, is the clearest recent example.[10] The dominant structural force over decades has not been consolidation but import substitution — offshore production hollowing out the domestic manufacturing base. Broader U.S. apparel manufacturing output fell about 17% in 2025 by one industry index, underscoring the pressure.[23]

9. Risks

• Import competition. Low-cost imports cap domestic pricing power and have shrunk the manufacturing base for decades.[9][23]
• Tariff and trade volatility. Section 301 duties on Chinese goods add roughly 7.5–25% on top of already-high most-favored-nation apparel rates, and 2025 escalation raised costs broadly.[32] Tariffs cut both ways: they can protect domestic makers and raise the cost of imported inputs those makers still buy.
• Forced-labor / supply-chain compliance. The Uyghur Forced Labor Prevention Act (UFLPA) presumes goods tied to Xinjiang are made with forced labor and bars entry; cotton is a high-priority target. CBP detained 6,636 shipments in just the first half of 2025 (versus 4,619 in all of 2024), and the entity list expanded to 144 names — raising sourcing cost and risk across cotton accessories.[33]
• Fashion and inventory risk. Style shifts (e.g., declining necktie use) can strand inventory in a category where trends turn fast.
• Thin margins and labor-cost inflation leave little cushion for domestic producers. Unit labor costs rose 12% from 2022 to 2024 while productivity fell.[20][21]
• Labor and automation. Domestic sewing, blocking, and finishing skills are difficult to rebuild after decades of offshoring. BLS expects robots and other technology to automate arranging, cutting, fitting, and sewing — a risk for legacy plants that cannot finance or utilize the equipment.[34]
• Customer concentration. Reliance on a few big retailers or licensors gives buyers pricing leverage.
• Consumer cyclicality. Discretionary accessories soften in downturns.
• For the few public plays, small-cap illiquidity and the fact that accessories are a minor slice of diversified businesses dilute any direct "industry" bet (e.g., Fossil's ~$232M market capitalization and multi-year revenue decline).[12]

10. How to invest, and the outlook

Public routes. There is no pure-play. Investors seeking exposure buy diversified apparel and fashion houses — VF Corporation (VFC), PVH (PVH), Ralph Lauren (RL), the accessories-tilted Fossil Group (FOSL), or retailer Genesco (GCO) — understanding that accessories are one line inside a much larger, largely import-based business, not a domestic-manufacturing bet.[12][15][14] Reserve any judgment on their dividend yields or valuation multiples for a company-level analysis; at the industry level, the honest statement is that the public market does not offer this industry directly.

Private routes are where the category actually lives: direct or private-equity ownership of branded accessory makers and licensing platforms (the Randa/New Era model); "Made in USA" and Berry-compliant niche manufacturers serving defense and premium buyers; industrial work-glove suppliers with steady B2B demand; and contract/private-label shops selling speed and customization. Small custom milliners and glove makers are search-fund and owner-operator territory. ACON's investment in New Era demonstrates the institutional-private-equity route.[16]

Near-term drivers to watch (these are forward-looking judgments, not settled facts):

• Tariffs and reshoring could modestly favor domestic niche and Berry-compliant makers if import costs stay elevated — but structural cost disadvantages and thin margins limit how much domestic manufacturing can grow.[32][23]
• De minimis suspension (effective August 2025) raises compliance and landed costs for direct-to-consumer foreign shipments, marginally helping domestic and conventional wholesale channels.[26]
• Forced-labor enforcement (UFLPA) looks set to keep tightening, raising sourcing costs and compliance burdens industry-wide and marginally improving the case for transparent domestic supply.[33]
• Licensed headwear remains the most attractive, most defensible corner — brandable, repeat-purchase, and consolidating — and is where the most investable value in the category is being created.[10]
• The broad category faces a secular fashion mix shift (ties down, streetwear headwear up) that rewards the right niches and punishes the wrong ones.

Bottom line: a small, fragmented, import-pressured domestic manufacturing industry wrapped inside a much larger accessories market whose value has migrated to brands, licenses, and importers. The best risk-adjusted exposure is private and brand-driven; public investors can only approximate it through diversified apparel names.

---

Sources

1. U.S. Census Bureau, "2022 NAICS Definition — 315990 Apparel Accessories and Other Apparel Manufacturing," 2022. https://www.census.gov/naics/?input=315990&year=2022
2. U.S. Census Bureau, "County Business Patterns (NAICS 315990)," 2023. https://www.census.gov/programs-surveys/cbp.html
3. Bureau of Labor Statistics, "Sectoral Output — NAICS 315990," via FRED. https://fred.stlouisfed.org/series/IPUEN315990T300000000
4. Bureau of Labor Statistics, "All Workers — NAICS 315990," via FRED. https://fred.stlouisfed.org/series/IPUEN315990W200000000
5. U.S. Census Bureau, "2022 NAICS Manual," 2022. https://www.census.gov/naics/reference_files_tools/2022_NAICS_Manual.pdf
6. U.S. Census Bureau, "2022 Economic Census — Concentration Ratios and Selected Statistics (NAICS 315990)," 2022. https://www.census.gov/programs-surveys/economic-census.html
7. Federal Reserve Board, "G.17 Industrial Production and Capacity Utilization — Value Added by Industry," 2022. https://www.federalreserve.gov/releases/g17/SandDesc/table1.17.htm
8. U.S. Small Business Administration, "Table of Small Business Size Standards," 2023. https://www.sba.gov/document/support-table-size-standards
9. First Research (Dun & Bradstreet), "Apparel Accessories Manufacturing Industry Profile," 2024. https://www.firstresearch.com/industry-research/Apparel-Accessories-Manufacturing.html
10. PR Newswire / National Sporting Goods Association, "New Era Completes Acquisition of '47," 2024. https://www.prnewswire.com/news-releases/new-era-completes-acquisition-of-47-302218138.html
11. PitchBook, "Randa Apparel & Accessories — Company Profile," 2026. https://pitchbook.com/profiles/company/10044-55
12. StockAnalysis / GuruFocus, "Fossil Group (FOSL) Financials — FY2025 Revenue," 2026. https://stockanalysis.com/stocks/fosl/
13. Ralph Lauren Corporation, SEC Form 10-K (Fiscal 2025), 2025. https://www.sec.gov/Archives/edgar/data/1037038/000103703825000011/rl-20250329.htm
14. Wikipedia, "VF Corporation" (founded 1899 as Reading Glove and Mitten Manufacturing Company), 2025. https://en.wikipedia.org/wiki/VF_Corporation
15. Genesco Inc., SEC Form 10-K (Lids Sports Group divestiture) and GlobalData company profile, 2019/2025. https://www.globaldata.com/company-profile/genesco-inc/
16. ACON Investments, "New Era to Acquire '47," 2024. https://aconinvestments.com/news/acon-portfolio-investment-new-era-to-acquire-47-creating-premier-global-sport-and-lifestyle-company/
17. Bollman Hat Company, company history, 2024. https://bollmanhats.com/about-us/our-heritage/
18. U.S. Made Supply / U.S. Department of Defense, "The Berry Amendment (10 U.S.C. 4862)," 2024. https://usmadesupply.com/resources/building-codes-standards/domestic-procurement/berry-amendment
19. Bureau of Labor Statistics, "Labor Share — NAICS 315990," via FRED. https://fred.stlouisfed.org/data/IPUEN315990L030000000
20. Bureau of Labor Statistics, "Labor Productivity — NAICS 315990," via FRED. https://fred.stlouisfed.org/series/IPUEN315990L000000000
21. Bureau of Labor Statistics, "Unit Labor Cost — NAICS 315990," via FRED. https://fred.stlouisfed.org/series/IPUEN315990U100000000
22. Bureau of Labor Statistics, "Output Price Deflator — NAICS 315990," via FRED. https://fred.stlouisfed.org/series/IPUEN315990T050000000
23. WWD / Sourcing Journal (Kearney Reshoring Index), "U.S. Apparel Manufacturing Fell 17% in 2025," 2025. https://wwd.com/sourcing-journal/trade/kearney-reshoring-index-usa-domestic-apparel-manufacturing-1238945612/
24. Bureau of Labor Statistics, "Consumer Expenditures — 2024," 2025. https://www.bls.gov/news.release/cesan.nr0.htm
25. Sports Business Journal, "NHL, New Era Reach Global Licensing Deal," 2024. https://www.sportsbusinessjournal.com/Articles/2024/07/09/nhl-new-era-global-licensing-deal/
26. U.S. Customs and Border Protection, "De Minimis Guidance," 2025. https://www.help.cbp.gov/s/article/Article-1050
27. U.S. Consumer Product Safety Commission, "Requirements for Textiles and Apparel / Flammable Fabrics Act," and Foley & Lardner, "What Apparel Companies Need to Know About the CPSC," 2024. https://www.cpsc.gov/Business--Manufacturing/Business-Education/Business-Guidance/Flammable-Fabrics-Act
28. U.S. Consumer Product Safety Commission, "Clothing FAQ," 2024. https://www.cpsc.gov/FAQ/Clothing
29. U.S. Federal Trade Commission, "Clothes Captioning: Complying with the Care Labeling Rule," 2023. https://www.ftc.gov/business-guidance/resources/clothes-captioning-complying-care-labeling-rule
30. U.S. Customs and Border Protection, "Textile Priority Trade Issue Fact Sheet," FY2024. https://www.cbp.gov/sites/default/files/2025-02/FY25%20Textile%20PTI%20Factsheet%203965-0125%20%28508%29%20%282%29.pdf
31. CalRecycle, "Textile Extended Producer Responsibility Program," 2026. https://calrecycle.ca.gov/epr/textiles/
32. White & Case LLP, "United States Finalizes Section 301 Tariff Increases on Imports from China," 2024. https://www.whitecase.com/insight-alert/united-states-finalizes-section-301-tariff-increases-imports-china
33. U.S. Customs and Border Protection / DHS, "Uyghur Forced Labor Prevention Act (UFLPA) Enforcement Statistics and 2025 Strategy Update," 2025. https://www.cbp.gov/trade/forced-labor/UFLPA
34. Bureau of Labor Statistics, "Factors Affecting Occupational Utilization," 2025. https://www.bls.gov/emp/tables/factors-affecting-occupational-utilization.htm