Country of origin determination for decorative pillow; 19 CFR 102.21(c)(2); tariff shift

N360834May 18, 2026OT:RR:NC:N2:349
CATEGORY: OriginMs. Jo-Anne DanielsJo-Anne Daniels DBA Trade Resources & Associates230-B Tyson AvenueParis, TN 38242RE: Country of origin determination for decorative pillow; 19 CFR 102.21(c)(2); tariff shiftDear Ms. Daniels:This is in reply to your letter dated
April 19, 2026
, submitted on behalf of your client, Crane USA Inc.,requesting a country of origin determination for decorative pillows which will be imported into the UnitedStates. Our office received a physical sample of Item CH-210DP-1 and photographs of Items CH-210DP-1,CH210DP-2, CH-220DP-6, CH-200DP-3 and CH-220DP-2. The sample of Item CH-210DP-1 will beretained by our office.Item #CH-210DP-1, described as both the “Dune Reversible Decorative Pillow” and the “SunriseTwo-Toned Pillow,” is a pillow consisting of a pillow insert covered with a lined decorative pillow coverwith a zipper closure. The pillow insert is made of a 100 percent cotton woven fabric shell that is stuffedwith 100 percent polyester microfill fiber. The decorative pillow cover is made of a compound 100 percentcotton woven fabric. The underlying warp and weft are of undyed yarns in a plain weave construction.Additional wefts of coarser, dyed, gimped yarns are inserted in bundles of 5 under every eighth warp. Thepillow cover is lined with a lightweight 100 percent cotton woven fabric. The cover is finished with a zipperclosure on one end, a knife edge finish on the opposite end and fringe on the two sides. The completedpillow measures 20 × 20 inches. The item is imported for retail sale under the Dune Collection of the CraneHome brand.Item #CH-210DP-2, described as both the “Dune Aztec Decorative Pillow” and the “Tribal Sun Pillow,” is apillow consisting of a pillow insert covered with a lined decorative pillow cover with a zipper closure. Thepillow insert is made of a 100 percent cotton woven fabric shell that is stuffed with 100 percent polyestermicrofill fiber. The decorative pillow cover is made of 100 percent cotton woven fabric. The face panel ismade from a rust-orange, yarn-dyed, woven fabric that is embroidered with a geometric tribal pattern. Theback panel is constructed of plain-woven fabric formed from dyed warp yarns and undyed weft yarns. Thepillow cover is lined with a lightweight 100 percent cotton woven fabric. The cover is finished with a zipperclosure on one side and knife edge finish on other three sides. The completed pillow measures 20 × 20inches. The item is imported for retail sale under the Dune Collection of the Crane Home brand.
Item #CH-220DP-6, described as both the “Zen Decorative Pillow” and the “Forest Path Pillow,” is a pillowconsisting of a pillow insert covered with a lined decorative pillow cover with a zipper closure. The pillowinsert is made of a 100 percent cotton woven fabric shell that is stuffed with 100 percent polyester microfillfiber. The decorative pillow cover is made of 100 percent cotton woven fabric. The face panel is wovenwith creme-colored undyed yarns. The fabric is embroidered with dyed yarns in a rectangular checkeredpattern over the majority of the center third of the surface area. The back panel is constructed of plain-wovenfabric formed from undyed yarns. The pillow cover is lined with a lightweight 100 percent cotton wovenfabric. The cover is finished with a zipper closure on one side and knife edge finish on other three sides. Thecompleted pillow measures 20 × 20 inches. The item is imported for retail sale under the Zen Collection ofthe Crane Home brand. Item# CH-200DP-3, described as both the “Calm Decorative Pillow” and the “Ivory Chevron Pillow,” is apillow consisting of a pillow insert covered with a lined decorative pillow cover with a zipper closure. Thepillow insert is made of a 100 percent cotton woven shell that is stuffed with 100 percent polyester microfillfiber. The decorative cover consists of a 56 percent wool, 39 percent cotton, and 5 percent other fiber facepanel that is woven in a chevron pattern with undyed cotton and wool yarns. The back panel of the cover isconstructed of a 100 percent cotton, cream-colored, undyed, plain-woven fabric. The pillow cover is linedwith a lightweight 100 percent cotton woven fabric. The cover is finished with a zipper closure on one sideand knife edge finish on other three sides. The completed pillow measures 18 × 18 inches. The item isimported for retail sale under the Calm Collection of the Crane Home brand.Item# CH-220DP-2, described as both the “Abstract Leaf Throw Pillow” and the “Abstract Leaf ThrowPillow,” is a pillow consisting of a pillow insert covered with a lined decorative pillow cover with a zipperclosure. The pillow insert is made of a 100 percent cotton woven shell that is stuffed with 100 percentpolyester microfill fiber. The decorative cover consists of a 94 percent cotton and 6 percent wool face panelthat is woven with undyed cotton and wool yarns. The fabric is embroidered with dyed yarns in a repeatingabstract pattern. The back of the cover is constructed of a 100 percent cotton plain-weave fabric of dyed andundyed yarns. The pillow cover is lined with a lightweight 100 percent cotton woven fabric. The cover isfinished with a zipper closure on one side and knife edge finish on other three sides. The completed pillowmeasures 18 × 18 inches. The item is imported for retail sale under the Zen Collection of the Crane Homebrand.The manufacturing operations for Item #CH-210DP-1, the “Dune Reversible Decorative Pillow,” are asfollows:Uzbekistan:Yarn is spun, singed, de-sized, scoured, and bleached.Cotton yarn for pillow cover’s outer surface is dyed, washed and dried.Cotton fabrics for the pillow cover and lining are woven.Cotton fabric for the outer shell of the pillow insert is woven.Polyester sewing thread is spun.Front, back, lining, and insert shell fabrics are stented, softened, shrunk and inspected.Rolls of finished cotton woven fabrics and spools of sewing thread are exported to India.India:Zipper, microfill and labels are manufactured.Fabrics are cut into panels for pillow cover, lining and pillow shell.Front and back panels, lining, and zipper are assembled by sewing to form the pillow cover.Pillow insert shell is assembled and sewn on three sides with labels attached, filled with loose fibers,and sewn closed.Pillow insert is placed inside the cover, and the cover is zipped closed.
Finished pillows are packed, boxed, palletized and exported to the United States.The manufacturing operations for Item #CH210DP-2, the “Dune Aztec Decorative Pillow,” are as follows:Uzbekistan:Yarn, including embroidery yarn, is spun, singed, de-sized, scoured and bleached.Colored yarns for front and back panels are dyed, washed and dried.Cotton fabrics for the pillow cover and lining are woven.Cotton fabric for the outer shell of the pillow insert is woven.Polyester sewing thread is spun.Front, back, lining, and insert shell fabrics are stented, softened, shrunk and inspected.Rolls of finished cotton woven fabrics and spools of embroidery yarn and sewing thread are exportedto India.India:Zipper, microfill, and labels are manufactured.Fabrics are cut into panels for pillow cover, lining and pillow shell.Front panel of the pillow cover is embroidered.Front and back panels, lining, and zipper are assembled by sewing to form the pillow cover.Pillow insert shell is sewn on three sides with labels attached, filled with loose fibers, and sewn closed.Pillow insert is placed inside the cover, and the cover is zipped closed.Finished decorative pillows are packed, boxed, palletized and exported to the United States.The manufacturing operations for Item #CH-220DP-6, the “Zen Decorative Pillow,” are as follows:Uzbekistan:Yarn, including embroidery yarn, is spun, singed, de-sized, scoured and bleached.Cotton fabrics for the pillow cover and lining are woven.Cotton fabric for the outer shell of the pillow insert is woven.Polyester sewing thread is spun.Embroidery yarn is dyed.Front, back, lining, and shell fabrics are stented, softened, shrunk and inspected.Rolls of finished cotton woven fabrics and spools of embroidery yarn and sewing thread are exportedto India.India:Zipper, microfill, and labels are manufactured.Fabrics are cut into panels for pillow cover, lining and pillow shell.Front panel of the pillow cover is embroidered.Front and back panels, lining, and zipper are assembled by sewing to form the pillow cover.Pillow insert shell is sewn on three sides with labels attached, filled with loose fibers, and sewn closed.Pillow insert is placed inside the cover, and the cover is zipped closed.Finished decorative pillows are packed, boxed, palletized and exported to the United States.The manufacturing operations for Item# CH-200DP-3, the “Calm Decorative Pillow” are as follows:Uzbekistan:Yarn is spun, singed, de-sized, scoured and bleached.
Fabric for front panel of the pillow cover is woven.Cotton fabric for the back panel of the pillow cover, lining and outer shell of pillow insert is woven.Polyester sewing thread is spun.Front, back, lining, and shell fabrics are stented, softened, shrunk and inspected.Rolls of finished fabrics for pillow covers, lining and outer shell for pillow insert and spools of sewingthread are exported to India.India:Zipper, microfill and labels are manufactured.Fabrics are cut into panels for pillow cover, lining and pillow shell.Front and back panels, lining, and zipper are assembled by sewing into a finished pillow cover.Pillow insert shell is sewn on three sides with labels attached, filled with loose fibers, and sewn closed.Pillow insert is placed inside the cover and, the cover is zipped closed.Finished decorative pillows are packed, boxed, palletized and exported to the United States.The manufacturing operations for Item# CH-220DP-2 the “Abstract Leaf Throw Pillow” are as follows:Uzbekistan:Yarn, including embroidery yarn, is spun, singed, de-sized, scoured, bleached, dyed, washed and dried.Cotton/wool fabric for front panel of the pillow cover is woven.Cotton yarn for the back panel fabric of the pillow cover is woven from dyed and undyed yarns.Cotton fabric for the pillow insert shell and lining is woven.Polyester sewing thread is spun.Front, back, lining, and shell fabrics are stented, softened, shrunk and inspected.Rolls of finished fabrics for pillow covers, lining and outer shell for pillow insert and spools of threadand embroidery yarn are exported to India. India:Zipper, microfill and labels are manufactured.Fabrics are cut into panels for pillow cover, lining and pillow shell.Front panel of the pillow cover is embroidered.Front and back panels, lining and zipper are assembled by sewing into a finished pillow cover.Pillow insert shell is sewn on three sides, filled with loose fibers, and sewn closed.Pillow insert is placed inside the cover and, the cover is zipped closed.Finished decorative pillows are packed, boxed, palletized 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 (“URAA”) (codified at 19 U.S.C. 3592), enacted onDecember 8, 1994, provides the rules of origin for textiles and apparel products for purposes of the customslaws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, orwithdrawn from warehouse, for consumption on or after July 1, 1996. Section 3592 has been described asCongress’s expression of substantial transformation as it relates to textile and apparel products. Section102.21 of the Code of Federal Regulations (19 CFR 102.21), implements the URAA. The country of originof a textile or apparel product shall be determined by the sequential application of the general rules set forthin 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 notwholly obtained or produced in a single country, territory or insular possession, paragraph (c)(1) of Section102.21 is inapplicable.Paragraph (c)(2) states, “Where the country of origin of a textile or apparel product cannot be determinedunder paragraph (c)(1) of this section, the country of origin of the good is the single country, territory, orinsular possession in which each of the foreign materials incorporated in that good underwent an applicablechange in tariff classification, and/or met any other requirement, specified for the good in paragraph (e) ofthis section:” Paragraph (e) in pertinent part states,The following rules shall apply for purposes of determining the country of origin of a textile orapparel product under paragraph (c)(2) of this section:HTSUS Tariff shift and/or other requirements9404.90Except for goods of subheading 9404.90 provided for in paragraph (e)(2) ofthis section, the country of origin of a good classifiable under subheading9404.90 is the country, territory, or insular possession in which the fabriccomprising 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.Paragraph (e)(2) in pertinent part states,For goods of HTSUS headings 6213 and 6214 and HTSUS subheadings 6117.10, 6302.22, 6302.29, 6302.52,6302.53, 6302.59, 6302.92, 6302.93, 6302.99, 6303.92, 6303.99, 6304.19, 6304.93, 6304.99, 9404.90.85 and9404.90.95, except for goods classified under those headings or subheadings as of cotton or of wool orconsisting of fiber blends containing 16 percent or more by weight of cotton:(i) The country of origin of the good is the country, territory, or insular possession in which the fabriccomprising the good was both dyed and printed when accompanied by two or more of the followingfinishing operations: bleaching, shrinking, fulling, napping, decating, permanent stiffening,weighting, permanent embossing, or moireing;(ii) If the country of origin cannot be determined under paragraph (e)(2)(i) of this section...the countryof origin is the country, territory, or insular possession in which the fabric comprising the good wasformed by a fabric-making process;The decorative pillows are not classified in a subheading subject to paragraph (e)(2) and all of the fabricscomprising the decorative pillows are formed in Uzbekistan. As the fabric-making process occurs in a singlecountry, that is, Uzbekistan, as per the terms of the tariff shift requirement, country of origin is conferred inUzbekistan.
HOLDING:The country of origin for Item #CH-210DP-1, the “Dune Reversible Decorative Pillow”; Item #CH-210DP-2,the “Dune Aztec Decorative Pillow”; Item #CH-220DP-6, the “Zen Decorative Pillow”; Item #CH-200DP-3,the “Calm Decorative Pillow”; and Item #CH-220DP-2, the “Abstract Leaf Throw Pillow,” is Uzbekistan,pursuant to 19 CFR 102.21(c)(2).The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Kim Wachtel at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division