RE: Country of origin determination for a lashing strap; 19 CFR 102.21(c)(2)

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363603 August 18, 2026 OT:RR:NC:N3:351 CATEGORY: Origin TARIFF NO.: 6307.90.9891 Ms. Edith Garcia Klein Tools Inc. 450 Bond Street Lincolnshire, IL 60069 RE: Country of origin determination for a lashing strap; 19 CFR 102.21(c)(2) Dear Ms. Garcia: In your letter, dated July 23, 2026, you requested a ruling on the country of origin of a lashing strap. In lieu of a sample, photographs of the item were provided with your request. SKU# 54936RMB, described as a “Lashing Strap,” is an adjustable webbed textile strap with a spring-loaded cam buckle at each end. The lashing strap consists of a dyed black woven fabric composed of 100 percent polypropylene filament yarns. The strap measuring 80 inches in length by 1 inch in width is threaded through a spring-loaded cam buckle at each end. The strap is intended to secure items to a modular toolbox, so the items remain in place while the box is being rolled or transported. You state the manufacturing operations for the lashing strap are as follows: China: The 100 percent polypropylene filament yarn is extruded, spooled, and shipped to Cambodia. Cambodia: The 100 percent polypropylene webbed fabric is woven, spooled, and shipped to China. China: The plastic and metal components are produced. The 100 percent polypropylene webbed fabric is cut to size. The plastic and metal components are assembled into a spring-loaded cam buckle. The webbed fabric is threaded through the spring-loaded cam buckle at each end. The completed lashing strap is packaged and shipped 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 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customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996.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)(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 lashing strap 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 lashing strap is formed by the fabric-making process in a single country, that is, Cambodia, as per the terms of the tariff shift requirement, the country of origin for the lashing strap is conferred in Cambodia. HOLDING: The country of origin of the lashing strap is Cambodia 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) James P. Forkan Director National Commodity Specialist Division