The Ammerican Apparel & Footwear Association asked its members not to respond directly to a survey by the trucking industry, arguing it requests proprietary information and could be used to justify massive rate hikes for apparel shippers. Instead, the AAFA wants member companies to divert their responses to it so it can produce its own study.


The survey was sent out to apparel companies to gather information for a study that will be used by the National Motor Freight Traffic Association's (NMFTA) Commodity Classification Standards Board (CCSB) when they vote on Oct. 4 on its proposal to change the classification for clothing (Public Docket 2010-3, Section II – Clothing).

The CCSB's proposal, if approved, would dramatically change the freight classification for clothing, which could lead to dramatic increases in domestic freight rates for clothing – anywhere from 25 to 400 percent.


The CCSB determines the classification for products under the National Motor Freight Classification (NMFC) which is used by many carriers in determining the domestic (US) freight rates they charge shippers for LTL (less than truckload) shipments. The CCSB is not a government agency. It is an entity under the auspices of and run by the National Motor Freight Traffic Association (NMFTA), a private trade association which represents over 950 motor carriers.


“As we have seen with the recent classification increase for footwear, domestic LTL freight rates for footwear increased significantly as a result of the classification change,” the AAFA said in an alert to its members.

Countering Research Project 1091


The CCSB uses a study on clothing density, Research Project 1091, to justify its proposal to change the freight classifications for clothing. Of the study's 75,000 data points on the density of clothing shipments, only a few dozen data points were provided by actual apparel companies.

Ahead of the CCSB's reconsideration of its proposal at the Oct. 4, 2010 CCSB meeting, AAFA wishes to create its own study, using data from the industry, to counteract the CCSB's own study.


The CCSB sent a survey to companies to collect the data in question.


However, the letter and survey provide no guarantees of confidentiality. Further, the letter and survey ask completely inappropriate questions that request proprietary information from companies that is unnecessary and unrelated to the purpose the study.


Therefore, AAFA requests that companies provide AAFA directly only with the data requested in the chart at the bottom of the survey. Please provide AAFA with the data requested in the chart for all LTL shipments, if possible, made by the company over a three to four week period.


AAFA will keep company data confidential, aggregate the data and only submit the aggregated data to the CCSB.