Country of origin determination for a bathmat; 19 CFR 102.21(c)(2); tariff shift

N346179
March 13, 2025
OT:RR:NC:N2:349
CATEGORY: Origin Sally Gifford Geodis USA 5101 S Broad St Philadelphia, PA 19112 RE: Country of origin determination for a bathmat; 19 CFR 102.21(c)(2); tariff shift Dear Ms. Gifford: This is in reply to your letter dated February 21, 2025, requesting a country of origin determination on behalf of your client, Town & Country Living, for a bathmat which will be imported into the United States. A sample bathmat was submitted with your request and will be retained by this office for training purposes. FACTS: The sample, Item# 980376790, is a plush bathmat. The bathmat consists of an exposed upper surface of plush acrylic knitted fabric of cut pile construction. The knitted fabric is laminated to a layer of foam, approximately ¾ inch thick, and is backed with a polyester mesh fabric with an application of styrene-ethylene-butylene-styrene (SEBS) to create a non skid surface. You state there is a layer of mesh between the exposed upper surface and the foam, as well; however, we did not detect this layer on the sample. The edges are finished with binding tape. The bathmat features a double picture frame design on its upper surface formed by heat embossing. The bathmat, measures 20 × 32 inches. The manufacturing operations for the bathmat are as follows: China Knitted plush pile face fabric is formed. Knitted mesh backing fabric is formed. Adhesive material is produced for lamination. Knitted binding tape is formed. Materials are shipped to Thailand Thailand Fabrics are cut to size.

Polyurethane foam is formed. Face fabric, foam and mesh fabric are laminated together. Edges are finished with knitted binding. The care label and cuff card are attached. The mat is packaged in the paperboard retail display. The finished product is shipped from the factory and exported to U.S. ISSUE: What is the country of origin of the subject merchandise? COUNTRY OF ORIGIN - LAW AND ANALYSIS: Section 334 of the Uruguay Round Agreements Act (“URAA”) (codified at 19 U.S.C. 3592), enacted on December 8, 1994, provides the rules of origin for textiles and apparel products for purposes of the customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996. Section 3592 has been described as Congress’s expression of substantial transformation as it relates to textile and apparel products. Section 102.21 of the Code of Federal Regulations (19 CFR 102.21), implements the URAA. The country of origin of a textile or apparel product shall be determined by the sequential application of the general rules set forth in paragraphs (c)(1) through (5) of section 102.21. See 19 CFR 102.21(c). Paragraph (c)(1) states, “The country of origin of a textile or apparel product is the single country, territory, or insular possession in which the good was wholly obtained or produced.” As the subject merchandise is not wholly obtained or produced in a single country, territory or insular possession, paragraph (c)(1) of Section 102.21 is inapplicable. Paragraph (c)(2) states, “Where the country of origin of a textile or apparel product cannot be determined under paragraph (c)(1) of this section, the country of origin of the good is the single country, territory, or insular possession in which each of the foreign materials incorporated in that good underwent an applicable change in tariff classification, and/or met any other requirement, specified for the good in paragraph (e) of this section:” The bathmat is classified as a floor covering under heading 5705, Harmonized Tariff Schedule of the United States (HTSUS). Paragraph (e) in pertinent part states, The following rules shall apply for purposes of determining the country of origin of a textile or apparel product under paragraph (c)(2) of this section: HTSUS Tariff shift and/or other requirements 5701-5705 A change to heading 5701 through 5705 from any other chapter. All of the materials make the tariff shift in a single country, that is, Thailand, where the knit plush pile face fabric, foam and knit mesh backing are laminated together. Therefore, as per the terms of the tariff shift requirement, the country of origin of this bathmat is conferred in Thailand. HOLDING: The country of origin of the plush knit bathmat, Item# 980376790, is Thailand. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations

(CFR), Section 177.9(b)(1). ?This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. ?In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. ?If you have any questions regarding the ruling, please contact National Import Specialist Kim Wachtel at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division