Country of origin determinations of a quilt; 19 CFR 102.21(c)(5), last country where an important assembly or manufacturing process occurred

N348703
June 3, 2025
OT:RR:NC:N4:463
CATEGORY: Origin Harry Yao Down Home LLC 402 Maxwell Avenue Greenwood, SC 29646 RE: Country of origin determinations of a quilt; 19 CFR 102.21(c)(5), last country where an important assembly or manufacturing process occurred Dear Mr. Yao: This ruling is being issued in response to your letter dated May 7, 2025, requesting a country-of-origin determination for a quilt that will be imported into the United States. In lieu of a sample, pictures and a product description were provided. FACTS The subject article is identified as the Heavyweight Linen Blend Quilt, with style numbers VSQTK, VSQTKP, and VSQTQ, comes in the following three sizes: The full/queen measures 94" (L) x 90" (W), the king measures 94" (L) x 106" (W), and the California king measures 94" (L) x 120" (W). The quilt face fabric is made of 70% rayon/30% linen woven fabric and the quilt back fabric is made of 100% cotton woven fabric. The fill is 100% cotton fiber on a non-woven 100% polypropylene (PP) scrim. The quilt has a 1/2" binding in all four sides. The manufacturing operations are as follows: CHINA The 70% rayon/30% linen face fabric is woven. The 100% PP scrim fabric is formed. The 100% cotton fill is produced and adhered to the scrim The fabrics and fill are exported to Vietnam. VIETNAM The back fabric is woven. The fill and scrim are placed between the front and back fabrics and quilted. The quilt is cut, sewn, washed and packaged for export to the United States. 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customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996.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 does not apply. 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:” Paragraph (e)(1) provides the rules that apply to determine the country of origin of a textile or apparel product under paragraph (c)(2) of this section. The applicable rule corresponding to heading 9404.90, Harmonized Tariff Schedule of the United States (HTSUS), 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 9404.90 Except for goods of subheading 9404.90 provided for in paragraph (e)(2) of this section, the country of origin of a good classifiable under subheading 9404.90 is the country, territory, or insular possession in which the fabric comprising the good was formed by a fabric-making process. The “fabric-making process” is defined in 102.21(b)(2) as “any manufacturing operation that begins with polymers, fibers, filaments (including strips), yarns, twine, cordage, rope, or fabric strips and results in a textile fabric.” We note that the classification of the quilt is among those subheadings listed in the paragraph (e)(2) exception and we therefore apply 19 CFR 102.21(e)(2)(i), which states: (i) The country of origin of the good is the country, territory, or insular possession in which the fabric comprising the good was both dyed and printed when accompanied by two or more of the following finishing operations: bleaching, shrinking, fulling, napping, decating, permanent stiffening, weighting, permanent embossing, or moireing: Since the fabrics used to produce the quilt were not both printed and dyed and did not undergo two or more of the aforementioned operations, the country of origin cannot be based on (e)(2)(i), above. We proceed to 19 CFR 102.21(e)(2)(ii), which states: (ii) If the country of origin cannot be determined under paragraph (e)(2)(i) of this section, except for goods of HTSUS subheading 6117.10 that are knit to shape or consist of two or more component

parts, the country of origin is the country, territory, or insular possession in which the fabric comprising the good was formed by a fabric-making process; Since the quilt is composed of a face fabric that was formed in China and a back fabric and scrim that were formed in Vietnam, there is no single “country in which the fabric comprising the good was formed.” Since the quilt is not knit to shape, the country of origin cannot be based on 19 CFR 102.21(e)(2)(iii), so we proceed to Section 102.21(c)(3), which states: Where the country of origin of a textile or apparel product cannot be determined under paragraph (c) (1) or (2) of this section: if the good was knit to shape, the country of origin of the good is the single country, territory, or insular possession in which the good was knit; or except for fabrics of chapter 59 and goods of headings 5609, 5807, 5811, 6213, 6214, 6301 through 6306, and 6308, and subheadings 6307.10, 6307.90, 9404.90, and 9619.00.31-33 if the good was not knit to shape and the good was wholly assembled in a single country, territory, or insular possession, the country of origin of the good is the country, territory, or insular possession in which the good was wholly assembled. Since the quilt is not knit to shape, Section 102.21(c)(3)(i) will not apply and because the quilt is among the listed exceptions, Section 102.21(c)(3)(ii) will not apply. Therefore, we proceed to 19 CFR 102.21(c)(4), which states: Where the country of origin of a textile or apparel product cannot be determined under paragraph (c)(1), (2) or (3) of this section, the country of origin of the good is the single country, territory, or insular possession in which the most important assembly or manufacturing process occurred. In the case of the subject merchandise, the most important manufacturing process occurs at the time of the fabric formation. Since the quilt’s face fabric is made in China, and the quilt’s back fabric and scrim are formed in Vietnam, where the quilt is subsequently cut and sewn, there is no single country in which the most important assembly or manufacturing process occurred. Therefore, Section 102.21(c)(4) does not apply, and we proceed to 19 CFR 102.21(c)(5), which states: Where the country of origin of a textile or apparel product cannot be determined under paragraph (c)(1), (2), (3) or (4) of this section, the country of origin of the good is the last country, territory, or insular possession in which an important assembly or manufacturing process occurred. Accordingly, since the quilt’s face, scrim, back fabric and fill are manufactured into a quilt in Vietnam, the origin of the subject quilt is Vietnam. (See HQRL 960337, NYRL N344771 and N348701.) The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is 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. If the facts are modified in any way, or if the goods do not conform to these facts at the time of importation, you should bring this to the attention of 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 Title 19 of the Code of Federal Regulations (19 CFR Part 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, contact National Import Specialist Seth Mazze at [email protected].
Sincerely,
(for) Steven A. Mack Director National Commodity Specialist Division