Country of origin determination for a feather bed protector and a comforter protector; 19 CFR 102.21(c)(2); tariff shift

N351354
August 7, 2025
OT:RR:NC:N2:349
CATEGORY: Origin Ms. Yaping Shan Hangzhou Joyce Household Textiles Co., Ltd. No.2675 Xinluo Road Xintang Street, Xiaoshan District Hangzhou 311201 China RE: Country of origin determination for a feather bed protector and a comforter protector; 19 CFR 102.21(c)(2); tariff shift Dear Ms. Shan: This is in reply to your letter dated July 15, 2025, requesting a country of origin determination for a feather bed protector and a comforter protector which will be imported into the United States. In lieu of a sample, photographs of the item were provided with your request. FACTS: The subject merchandise, identified as a “Comforter Protector” and a “Featherbed Protector,” are encasement covers designed to protect a comforter or featherbed from bed bugs, dust mites and allergens. The protectors are composed of 100 percent cotton woven fabric which has been dyed white. The items are not stuffed or filled. The protectors feature an opening with a hidden zipper closure located at the bottom end. In addition, the comforter protectors feature a pair of internal self-fabric ties at all four corners designed to prevent the comforter from shifting inside the protector. The comforter protector is imported in standard bed sizes: Twin, 72” x 92”; Full, 86” x 92”; Queen, 92” x 97”; and King, 110” x 98.” The featherbed protector includes a 3-inch side gusset and is imported in sizes: Twin, 39" x 75" x 3”; Twin XL, 39" x 80" x 3”; Full, 54" x 75" x 3”; Queen, 60" x 80" x 3”; and King, 78" x 80” x 3”. The “Comforter Protector” and “Featherbed Protector” are available in the following SKU and product numbers: Name SKU# Product# CMF PROTECTOR TWIN WHITE 11103G-T-WHITE 25CP01 CMF PROTECTOR FULL WHITE 11103G-F-WHITE 25CP02 CMF PROTECTOR QUEEN WHITE 11103G-Q-WHITE 25CP03 CMF PROTECTOR KING WHITE 11103G-K-WHITE 25CP04 FEATHERBED PROTECTOR TWIN WHITE 11099G-T-WHITE 25FP01

FEATHERBED PROTECTOR TWIN XL WHITE 11099G-TXL-WHITE 25FP02 FEATHERBED PROTECTOR FULL WHITE 11099G-F-WHITE 25FP03 FEATHERBED PROTECTOR QUEEN WHITE 11099G-Q-WHITE 25FP04 FEATHERBED PROTECTOR KING WHITE 11099G-K-WHITE 25FP05 The manufacturing operations for the featherbed protector and comforter protector are as follows: Pakistan: Cotton woven fabric for the face and back is formed. Fabric is shipped in rolls to China. China: Fabric is bleached and dyed. Fabric is cut and assembled by sewing into the protector. Protectors are packaged and shipped to 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 (“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:” 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 6301-6306 Except for goods of heading 6302 through 6304 provided for in paragraph (e)(2) of this section, the country of origin of a good classifiable under heading 6301 through 6306 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 follows: A fabric-making process is any manufacturing operation that begins with polymers, fibers, filaments (including strips), yarns, twine, cordage, rope, or fabric strips and results in a textile fabric Based on the information provided in your letter, the comforter and featherbed protectors are classified under subheading 6302.31, Harmonized Tariff Schedule of the United States (HTSUS), which is not included in the paragraph (e)(2) exception to the above tariff shift rule. Therefore, as the fabric comprising the featherbed and comforter protectors is formed in a single country, that is, Pakistan, country of origin is conferred in Pakistan. HOLDING: The country of origin of the featherbed and comforter protectors is Pakistan pursuant of 19 CFR 102.21(c)(2). 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,
(for) James Forkan Acting Director National Commodity Specialist Division