Country of origin determination for a seat cushion; 19 CFR 102.21(c)(1); wholly obtained or produced in a single country
Issued May 5, 2025 by U.S. Customs and Border Protection.
Tariff classification
Product description
What is the country of origin of the subject merchandise? COUNTRY OF ORIGIN - LAW AND ANALYSIS: Section 334 of the Uruguay Round Agreements Act (codified at 19 U.S.C. 3592), enacted on December 8, 1994, provided rules of origin for textiles and apparel entered or withdrawn from warehouse for consumption, on and after July 1, 1996. Section 102.21, Customs Regulations (19 C.F.R. 102.21), published September 5, 1995, in the Federal Register, implements Section 334 (60 FR 46188). Section 334 of the URAA was amended by section 405 of the Trade and Development Act of 2000, enacted on May 18, 2000, and accordingly, section 102.21 was amended (68 Fed. Reg. 8711). Thus, 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. 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 seat cushion, part number BOZ73145001.2, was wholly obtained or produced in a single country, Cambodia, the country of origin is conferred in Cambodia.
CBP rationale
Section 334 of the Uruguay Round Agreements Act (codified at 19 U.S.C. 3592), enacted on December 8, 1994, provided rules of origin for textiles and apparel entered or withdrawn from warehouse for consumption, on and after July 1, 1996. Section 102.21, Customs Regulations (19 C.F.R. 102.21), published September 5, 1995, in the Federal Register, implements Section 334 (60 FR 46188). Section 334 of the URAA was amended by section 405 of the Trade and Development Act of 2000, enacted on May 18, 2000, and accordingly, section 102.21 was amended (68 Fed. Reg. 8711). Thus, 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. 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 seat cushion, part number BOZ73145001.2, was wholly obtained or produced in a single country, Cambodia, the country of origin is conferred in Cambodia.
Full text
N347513
May 5, 2025
OT:RR:NC:N4:463
CATEGORY: Country of Origin Irene Yuan Higher Technology (Cambodia) Co. Ltd. Land#189, Road 140, Bak Chenhchien Village, Trapeang Kong Commune, Samroang Tong District, Kampong Speu Province. Phnom Penh 050113 Cambodia RE: Country of origin determination for a seat cushion; 19 CFR 102.21(c)(1); wholly obtained or produced in a single country Dear Ms. Yuan: This ruling is being issued in response to your letter dated April 7, 2025, requesting a country-of-origin determination for a velour seat cushion. In lieu of a sample, pictures, product descriptions, a bill of materials and an explanation of the manufacturing operations were provided. The subject seat cushion, part number BOZ73145001.2, is designed to raise up the user and provide additional cushioning. It is comprised of a 100% polyester black velour knit fabric encasing a contoured memory foam bun. A zipper in the back allows for the insertion and removal of the bun. Although the article is described only as a “seat cushion,” it was submitted with a photo of the cushion placed in the driver’s seat of a car and may be used therein, as well as in other situations where its padding and/or height are desired. MATERIALS: The seat cushion is comprised of the following Cambodian components: 100% polyester velour fabric Memory foam bun Polyester thread Metal zipper Label The manufacturing operations are as follows: CAMBODIA:
The memory foam bun is produced. The velour fabric is knit. The zipper and label are produced. The fabric is cut and sewn together with the zipper and label to produce a seat cushion cover. The foam bun is inserted into the seat cushion cover and zipped shut to produce the seat cushion. The seat cushion is packaged and exported to the United States. 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 (codified at 19 U.S.C. 3592), enacted on December 8, 1994, provided rules of origin for textiles and apparel entered or withdrawn from warehouse for consumption, on and after July 1, 1996. Section 102.21, Customs Regulations (19 C.F.R. 102.21), published September 5, 1995, in the Federal Register, implements Section 334 (60 FR 46188). Section 334 of the URAA was amended by section 405 of the Trade and Development Act of 2000, enacted on May 18, 2000, and accordingly, section 102.21 was amended (68 Fed. Reg. 8711). Thus, 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. 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 seat cushion, part number BOZ73145001.2, was wholly obtained or produced in a single country, Cambodia, the country of origin is conferred in Cambodia. HOLDING: The country of origin of the seat cushion, part number BOZ73145001.2, is Cambodia. The holding set forth above applies only to the specific factual situation and merchandise description 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 Seth Mazze at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division
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