The country of origin determination for an unfinished face mask; 19 CFR 102.21(c)(2)

N356450
December 9, 2025
OT:RR:NC:N3:351
CATEGORY: Country of Origin Mr. Bryan Shields NuCare LLC 4201 Sierra Point Drive, Suite 102 Sacramento, CA 95834 RE: The country of origin determination for an unfinished face mask; 19 CFR 102.21(c)(2) Dear Mr. Shields: In your letter dated November 25, 2025, you requested a ruling on the country of origin of an unfinished face mask. Samples were provided to this office and will be retained for training purposes. The item, described as a “Semi-Finished Non-Woven Mask,” is an unfinished unisex disposable face mask that is intended to be used as a protective face covering. The unfinished face mask is composed of three layers of 100 percent polypropylene spunbonded nonwoven fabric. The pleated 7 inch in length by 3 ½ inch in width unfinished face mask features an aluminum strip on the top edge which lies on the bridge of the nose to help the mask conform to the contours of the face and is available in a variety of colors. After importation into the United States, the face mask is finished by attaching an elastic ear loop to each side of the mask. You state the manufacturing operations for the unfinished face mask are as follows: Vietnam: -100 percent polypropylene spunbonded nonwoven fabric is produced and shipped in rolls to China. - Aluminum nose bridge strip is produced. China: - Cutting, folding, and embossing of the fabric. - The unfinished face mask is packaged and shipped to the United States. ISSUES: 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at 19 U.S.C. 3592), enacted on December 8, 1994, provided rules of origin for textiles and apparel entered, or withdrawn from warehouse for consumption, on and after July 1, 1996.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 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)(1) provides the rules used to determine the country of origin of a textile or apparel product under paragraph (c)(2) of this section. These rules are dependent on the classification of the good. The unfinished face mask is classified under subheading 6307.90.9891, 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 6307.90 The country of origin of a good classifiable under subheading 6307.90 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 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 for the unfinished face mask is formed by the fabric-making process in a single country, that is, Vietnam, as per the terms of the tariff shift requirement, the country of origin for the unfinished face mask is conferred in Vietnam. HOLDING: The country of origin of the unfinished face mask is Vietnam 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 Kristine Dodge at [email protected].
Sincerely,
(for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division