RE: Country of origin determination for a quilt and pillow sham; 19 CFR 102.21(c)(2); tariff shift

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 N364336 September 16, 2026 OT:RR:NC:N2:349 CATEGORY: Origin Mr. Max Meng Chanco Global Holding Limited 19/F 83 Des Voeux Road Hong Kong China RE: Country of origin determination for a quilt and pillow sham; 19 CFR 102.21(c)(2); tariff shift Dear Mr. Meng: This is in reply to your letter dated August 17, 2026, requesting a country of origin determination for a quilt and a quilted pillow sham, which will be imported into the United States. Schematic drawings and a technical specification sheet were submitted in lieu of a sample. FACTS: The item identified as the “Quincy Quilt” is a quilt constructed in five layers: face and back panels of 100 percent cotton woven fabric; two internal layers of 100 percent olefin nonwoven scrim and a middle layer of 100 percent polyester batting. The outer face is printed to resemble a pieced patchwork pattern in alternating pink, blue, and cream vintage floral motif squares. The back panel is printed with a single all-over floral motif on a cream background. The five layers are quilted together in a diamond pattern. The edges of the quilt are finished with a ½ inch wide strip of 100 percent cotton woven printed binding with mitered corners. The quilt contains no embroidery, lace, braid, edging, trimming, piping, or applique work. The quilt is available in two sizes: Full/Queen (90 x 92 inches) SKU# 600P25252001 and King (108 x 92 inches) SKU# 600P25253001. The item identified as the “Quincy Sham” is a coordinating quilted face pillow sham in the same fabrics, print and construction as the Quincy Quilt. The back of the sham matches the back of the quilt and features an opening with a hidden zipper closure near the binding at the bottom of the sham. The sham contains no embroidery, lace, braid, edging, trimming, piping, or applique work. The quilted sham is available in two sizes: Standard (20" x 26") SKU# 600P25255001 and King (20" x 36") SKU# 600P25254001. The quilt and sham are packaged and sold separately under the Lauren Ralph Lauren Home® brand.
The manufacturing operations for the quilt and sham are as follows: VIETNAM: 100 percent cotton greige fabric is woven. 100 percent polyester batting is formed. 100 percent olefin nonwoven scrim is formed. 100 percent polyester sewing thread is formed. Cotton woven greige fabric for the front and back panels is exported to China. Fabrics are cut into panels and binding fabric is cut into strips for both comforter and shams. Polyester batting and olefin nonwoven scrim panels are placed between the face and backing panels and quilted. Hidden zipper is sewn along bottom edge of the sham’s backing fabric. Binding is sewn to all edges. The quilt and quilted sham are packaged separately for retail sale and exported to the United States. CHINA: The cotton fabrics undergo printing, bleaching, and shrinking. Zipper is manufactured. Finished fabric and zipper component are exported to Vietnam. 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:” We note that the subject quilts are classified in subheading 9404.40.10, Harmonized Tariff Schedule of the United States (HTSUS), and the subject sham is classified in subheading 9404.90.81, HTSUS. Prior to 2022, the corresponding HTSUS classification for subheadings 9404.40.10, HTSUS, and 9404.90.81, HTSUS, was subheading 9404.90.80, HTSUS. The tariff shift rules have not yet been updated to the current subheadings; therefore, we will follow the rule corresponding to the prior subheading, in the analysis below.
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 9404.90 Except for goods of subheading 9404.90 provided for in paragraph (e)(2) of this section, the country of origin of a good classifiable under subheading 9404.90 is the country, territory, or insular possession in which the fabric comprising the good was formed by a fabric-making process. Subheadings 9404.40.10 and 9404.90.81 (formerly 9404.90.80), HTSUS, are not included in the paragraph (e)(2) exception to the above tariff-shift rule. 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 all of the fabrics are formed in a single country, that is, Vietnam, as per the terms of the tariff shift requirement, country of origin is conferred in Vietnam. HOLDING: The country of origin of the quilt and quilted sham is Vietnam pursuant 102.21(c)(2). The tariffs and additional 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 provided at https://hts.usitc.gov/. 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) James P. Forkan Director National Commodity Specialist Division