Classification and Country of Origin Determination for a Backpack; Substantial Transformation

N363601August 12, 2026OT:RR:NC:N4:441
CATEGORY: Classification, Origin
TARIFF NO.: 4202.92.4500
Kristy erez-NaranjoPD&B Customs Brokers, LLC8751 NW 11th StreetPembroke Pines, FL 33024RE: Classification and Country of Origin Determination for a Backpack; Substantial TransformationDear Ms. Perez-Naranjo:This is in reply to your letter dated
July 23, 2026
, on behalf of your client ZSA Technology Labs, requestinga classification and country of origin determination for a backpack, which will be imported into the UnitedStates.FACTS:The subject merchandise is a backpack constructed of textile material with an outer surface of plasticsheeting. The article is designed to provide storage, protection, organization, and portability to personaleffects during travel. The back of the pack has two straps that allow the user to wear it over the shoulders onthe back.The manufacturing operations for the backpack are as follows: United StatesThe fabric is manufacturedIndonesiaReceipt and inspection of all raw materials andcomponents Pattern preparation and material cutting (including the d accessoryfabric panels, lining, reinforcement, an materials)Sewing and assembly operationsInstallation of zippers,webbing, straps, hardware, and accessories; Construction ofcompartments
Quality control, labeling, final assembly, finishingand packaging for export. ISSUE:What are the classification and country of origin of the subject merchandise?CLASSIFICATION:The applicable subheading will be 02.92.4500, for the backpack 42Harmonized Tariff Schedule of the UnitedHTSUS, which provides for travel, sports, and similar bags, with outer surface of sheeting of plasticStates (), other. The general rate of duty will be 20 percent ad valorem.or of textile materialThe duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS.Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies.COUNTRY OF ORIGIN:When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether asubstantial transformation will occur is whether an article emerges from a process with a new name,character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).The fabric emerges with a new name, character and use as a result of the cutting, sewing, and other processesperformed Indonesia. As such, the country of origin of the subject backpack is Indonesia.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 contact National Import Specialist Vikki Lazaro [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division