Ms. Alice Lu
Printx GP (Cambodia) Factory Co., Ltd
National Road # 51, Trapeang Phlong Village,
Damnak Reang Commune, Oudong District,
Kampong Speu Province, Cambodia 050413

RE: The tariff classification and country of origin of a baseball-style woven hat; 19 CFR 102.21(c)(2)

Dear Ms. Lu:

In your letter, dated June 22, 2022, you requested the tariff classification and country of origin for a cargo bag, a drawstring bag, and a hat on behalf of your client, Lowe's Companies, Inc. You submitted photographs with your request. You state the items will be packed together for retail sale. Although the items are put up together for retail sale and consist of at least two different articles which are classifiable in different headings, the items are not put together to meet a particular need or to carry out a specific activity. Therefore, the items are not eligible for classification as a set and will be classified separately. Consequently, CBP requested the items be separated into two requests for a ruling, one for the hat, the other for the bags. Subsequently, you sent a letter, dated July 8, 2022, requesting the tariff classification and country of origin for the hat. This ruling covers classification of the hat. The cargo bag and drawstring bag are separately addressed in N326742.


The subject article, identified as "Kobalt 16" Cargo bonus pack-ins, item# 5064409," consists of a tool bag, a drawstring backpack and a baseball-style hat. The tool bag and the drawstring backpack are addressed in ruling N326742. In your submission and subsequent correspondence you indicate the hat is constructed of 100 percent polyester woven fabric. The buckram structured hat features five panels with eyelets on the front, a fabric covered button on the top of the crown, a distinctive visor and an adjustable plastic closure on the back. The letter K is embroidered on the front center of the cap.

You have indicated that the locations of the manufacturing operations are as follows:


The polyester fabric and all materials (hat visor core, plastic snapback and sewing thread) are manufactured.


All cutting, sewing, and assembly are performed.


What are the classification and country of origin of the subject merchandise?


The applicable subheading for the Kobalt Hat will be 6505.00.8090, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for "Hats and other headgear, knitted or crocheted, or made up from lace, felt or other textile fabric, in the piece (but not in strips), whether or not lined or trimmed; hair-nets of any material, whether or not lined or trimmed: Other: Other: Of man-made fibers: Other: Not in part of braid: Other: Other: Other." The rate of duty will be 18.7 cents per kilogram plus 6.8 percent ad valorem.

In your letter, you request the classification and country of origin of the hat for the purpose of claiming preference under the Generalized System of Preferences (GSP). Please note 6505.00.8090, HTSUS, is not eligible for preference under the GSP as the tariff does not include GSP ("A") in the special rate column in the tariff. Also, please be aware Vietnam is no longer listed as a beneficiary developing country in General Note 4, HTSUS, for the purpose of claiming preference under the GSP.

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 on the World Wide Web at


You also requested a country of origin determination. 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 CFR 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." Since 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) 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

6505.00 (3) For any other good, if the good consists of two or more components, a change to subheading 6505.00 from any other heading, provided that the change is the result of the good being wholly assembled in a single country, territory or insular possession.

C.F.R Section 102.21(b)(6) defines "wholly assembled" as:

The term "wholly assembled" when used with reference to a good means that all components, of which there must be at least two, preexisted in essentially the same condition as found in the finished good and were combined to form the finished good in a single country, territory, or insular possession. Minor attachments and minor embellishments (for example, applique, beads, spangles, embroidery, buttons) not appreciably affecting the identity of the good, and minor subassemblies (for example, collars, cuffs, plackets, pockets), will not affect the status of a good as "wholly assembled" in a single country, territory, or insular possession.

The subject merchandise meets the "wholly assembled" definition because it is composed of at least two components (polyester woven fabric, visor core and plastic snapback) that are assembled in Vietnam. Therefore, it meets the tariff shift requirement for subheading 6505.00 HTSUS, in Section 102.21(c)(2).


The country of origin of the subject item is Vietnam.

The holding set forth above applies only to the specific factual situation and merchandise identified in the ruling request. This position is clearly set forth in section 19 CFR 177.9(b)(1). This section states that a ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). Should it be subsequently determined that the information furnished is not complete and does not comply with 19 CFR 177.9(b)(1), the ruling will be subject to modification or revocation. In the event there is a change in the facts previously furnished, this may affect the determination of country of origin. Accordingly, if there is any change in the facts submitted to Customs, it is recommended that a new ruling request be submitted in accordance with 19 CFR 177.2.

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, contact National Import Specialist Katherine Souffront at [email protected]


Steven A. Mack
National Commodity Specialist Division