ISPA submitted written comments in response to the U.S. Trade Representative’s (USTR) request for comments on whether particular tariff exclusions warrant extension beyond November 29, 2025. ISPA’s comments discuss the current Section 301 tariff exclusion for Flame Resistant Textile Staple Fibers of Viscose Rayon (Viscose Rayon) and request that this exclusion be extended. 

These fibers are essential for mattress manufacturers to meet federally mandated flammability requirements. Unfortunately, Viscose Rayon is not manufactured in the U.S., and the fibers are not available in the quantities or quality necessary for U.S. manufacturers outside of China. ISPA’s comments emphasize that domestic mattress manufacturers need critical inputs, such as Viscose Rayon, to be cost-competitive to compete with manufacturers outside of the U.S. ISPA believes renewing the exclusion is consistent with the USTR’s 2025 Trade Policy Agenda, which emphasizes strengthening domestic supply chains, supporting American workers, and promoting economic resilience.    

Please contact ISPA’s government affairs team (Alison Keane and Marty Salamone) with any questions.