Country of origin determination for eyewear cleaning cloths; 19 CFR 102.21(c)(2); tariff shift

N353787
October 16, 2025
OT:RR:NC:N2:349
CATEGORY: Origin Ms. Cristiana Bonomelli ZPC Srl a Socio Unico - Società Benefit Piazzetta Scala Verona Italy RE: Country of origin determination for eyewear cleaning cloths; 19 CFR 102.21(c)(2); tariff shift Dear Ms. Bonomelli: This is in reply to your letter dated September 16, 2025, requesting a country of origin determination for an eyewear cleaning cloth, which will be imported into the United States. In lieu of a sample, photographs were submitted with your request. FACTS: The subject merchandise, SKU #92-014-256, described as an eyewear cleaning cloth is designed to clean eyeglass lenses. The cleaning cloth is made from 80 percent polyester and 20 percent nylon brushed knit fabric, dyed white. The face side of the cleaning cloth is either printed or embossed with the company’s name and logo “ESSILOR Crizal®” along the bottom edge. The cloth measures 17 × 17 centimeters square and has pinked edges. You state the cloth is packaged in a plastic bag together with a certificate card of authenticity for retail sale. The manufacturing operations for the eyewear cleaning cloth are as follows: Cambodia: Fabric is knit from yarns formed in China. Fabric is shipped in rolls to China. China: Yarn is produced and shipped to Cambodia. Fabric is dyed and/or brushed. Fabric is cut to desired size. “ESSILOR Crizal®” logo is applied on the cleaning cloth.

Cleaning cloth is folded and packaged into a plastic bag together with a certificate card of authenticity and shipped to the 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customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996.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:” 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 6307.10 The country of origin of a good classifiable under subheading 6307.10 is the country, territory, or insular possession in which the fabric comprising the good was formed by the 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. As the fabric forming the cleaning cloth is formed by the fabric-making process in a single country, that is, Cambodia, as per the terms of the tariff shift requirement, country of origin is conferred in Cambodia. HOLDING: The country of origin of the eyewear cleaning cloth, SKU #92-014-256, is Cambodia pursuant 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division