OT:RR:NC:N4:463
Andrea Abraham
Meeks, Sheppard, Leo & Pillsbury LLP
570 Lexington Avenue, 24th Floor
New York, NY 10022
RE: Country of origin determination of a quilt, quilted sham, quilt set, and quilted euro sham;
19 CFR 102.21(c)(4); most important assembly or manufacturing process
Dear Ms. Abraham:
This ruling is being issued in response to your letter dated March 20, 2025, requesting a country-of-origin
determination on behalf of your client, Levtex LLC, for a quilt, quilted sham, quilt set, and euro sham. In
lieu of samples, pictures and product descriptions were provided.
The first article, the English Forest Natural Quilt, is available as a Twin (68" x 86") with style number
L60910T, as a Full/Queen (88" x 92") with style number L60910FQ, and as a King (106" x 92") with style
number L60910K. The quilt (face, back, and binding) is made of 100% cotton woven fabric with a 90%
cotton/10% polyester blended fill on a polyester scrim. The quilt face displays an arboreal forest print, and
the quilt back displays small grey diamonds on an off-white background. The approximately 1" quilting runs
horizontally. There is no embroidery, lace, braid, edging, trimming, piping exceeding 6.35 mm or applique
work.
The second article, the English Forest Natural Sham, is available as a Standard Sham (20" x 26") with style
number L60910SH, as a King Sham (20" x 36") with style number L60910SHK, and as a Euro Sham (26" x
26") with style number L60910SHE2. The sham (face, back, and binding) is made of 100% cotton woven
fabric with a 90% cotton/10% polyester blended fill on a thin polyester scrim. The pillow sham face displays
an arboreal forest print, and the pillow sham back displays small grey diamonds on an off-white background.
There is no embroidery, lace, braid, edging, trimming, piping exceeding 6.35 mm or applique work.
The third article, the English Forest Natural Set, is available in three options: The English Forest Natural
Twin Quilt Set, style number L60910TS, which consists of 1 quilt and 1 sham, the English Forest Natural
Full/Queen Quilt Set, style number L60910FQS, which consists of 1 quilt and 2 standard shams, and the
English Forest Natural King Quilt Set, style number L60910KS, which consists of 1 quilt and 2 King shams.
The sizes for each correspond to those in the previous two paragraphs.
The fourth article, the English Forest Euro Sham, with style number L60910SHE2, is identical to the shams
in article 2, above, with the sole distinction that it measures 26" x 26", and will be imported and sold
separately.
The manufacturing operations are as follows:
PAKISTAN
1. Yarn is woven into cotton face and back fabrics.
2. The fabrics are exported to China.
CHINA
1. The cotton face and back fabrics are printed.
2. The quilting fill (250 gsm), with a 90% cotton and 10% polyester fiber content, is produced and
attached to a thin polyester scrim.
3. The face fabric, fill, and back fabric are sewn together on a quilting machine, using polyester
thread to produce the quilted fabric.
4. The quilted fabric is cut to size.
5. The edges of the quilted fabric are bound using either the front or back fabric and labels are sewn
in to finish the quilt.
6. The manufacturing process for the shams is the same as that described above for the quilts with
the following additional step: once the quilted fabric is cut to sham size, the printed back fabric is
sewn to both ends of the quilted front panel to form the sham back, leaving a small overlap in the
middle for the insertion of a pillow inner (not included). The small overlap will be held shut with
small fabric ties.
COUNTRY OF ORIGIN
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 entered, or withdrawn from
warehouse for consumption, on and after July 1, 1996. Section 102.21 of the Code of Federal Regulations
(19 C.F.R. § 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 C.F.R. § 102.21(c).
At the outset, we consider the Quilt Set to be a set under the General Rules of Interpretation (GRI). Section
102.21(d) addresses the treatment of sets for country-of-origin purposes. Section 102.21(d) provides the
following:
Where a good classifiable in the Harmonized Tariff Schedule of the United States (HTSUS) as a set
includes one or more components that are textile or apparel products and a single country of origin for
all of the components of the set cannot be determined under paragraph (c) of this section, the country
of origin of each component of the set that is a textile or apparel product shall be determined
separately under paragraph (c) of this section.
Thus, per the terms of Section 102.21(d), the country of origin of each item in the set must be determined
separately if there is not a single country of origin for the entire set.
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 does not apply.
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 that apply to determine the country of origin of a textile or apparel
product under paragraph (c)(2) of this section. The applicable rule corresponding to heading 9404.90,
Harmonized Tariff Schedule of the United States (HTSUS), states:
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.
The “fabric-making process” is defined in 19 CFR 102.21(b)(2) as “any manufacturing operation that begins
with polymers, fibers, filaments (including strips), yarns, twine, cordage, rope, or fabric strips and results in a
textile fabric.”
We note that the classification of the quilts and shams is among those subheadings listed in the paragraph
(e)(2) exception and we therefore apply 19 CFR 102.21(e)(2)(i), which states:
(i) The country of origin of the good is the country, territory, or insular possession in which the fabric
comprising the good was both dyed and printed when accompanied by two or more of the following
finishing operations: bleaching, shrinking, fulling, napping, decating, permanent stiffening,
weighting, permanent embossing, or moireing:
Since the fabrics used to produce the quilts and shams were only printed, and not both printed and dyed and
did not undergo two or more of the requisite finishing operations, the country of origin cannot be based on
(e)(2)(i), above.
We proceed to 19 CFR 102.21(e)(2)(ii), which states:
(ii) If the country of origin cannot be determined under paragraph (e)(2)(i) of this section, except for
goods of HTSUS subheading 6117.10 that are knit to shape or consist of two or more component
parts, the country of origin is the country, territory, or insular possession in which the fabric
comprising the good was formed by a fabric-making process;
Since the quilts and shams are composed of face and back fabrics woven in Pakistan, and fill held in place by
a thin polyester scrim fabric formed in China, there is no single “country in which the fabric comprising the
good was formed.”
Since neither the quilts nor the shams were knit to shape, the country of origin cannot be based on 19 CFR
102.21(e)(2)(iii), so we proceed to Section 102.21(c)(3), which states:
Where the country of origin of a textile or apparel product cannot be determined under paragraph (c)
(1) or (2) of this section: (i) If the good was knit to shape, the country of origin of the good is the
single country, territory, or insular possession in which the good was knit; or (ii) Except for fabrics of
chapter 59 and goods of headings 5609, 5807, 5811, 6213, 6214, 6301 through 6306, and 6308, and
subheadings 6307.10, 6307.90, 9404.90, and 9619.00.31-33 if the good was not knit to shape and the
good was wholly assembled in a single country, territory, or insular possession, the country of origin
of the good is the country, territory, or insular possession in which the good was wholly assembled.
Since the quilts and shams will not be knit to shape, Section 102.21(c)(3)(i) will not apply and because the
quilts and shams are among the listed exceptions, Section 102.21(c)(3)(ii) will not apply. Therefore, we
proceeding to 19 CFR 102.21(c)(4), which states:
Where the country of origin of a textile or apparel product cannot be determined under paragraph
(c)(1), (2) or (3) of this section, the country of origin of the good is the single country, territory, or
insular possession in which the most important assembly or manufacturing process occurred.
In this case, the most important assembly or manufacturing process is the fabric making process
corresponding to the quilt?s face and back fabrics. ?Accordingly, since the quilt face and quilt back fabrics
will be formed in Pakistan, the country of origin of the quilt and the sham will be Pakistan. ?(See NYRL
N306314.)
HOLDING
Based upon the foregoing analysis, the country of origin of the article 1, English Forest Natural Quilt, with
style numbers L60910T, L60910FQ, and L60910K, and article 2, the English Forest Natural Sham, with style
numbers L60910SH, L60910SHK, and L60910K, and article 3, the English Forest Natural Set, with style
numbers L60910TS, L60910FQS and L60910KS, and article 4, the English Forest Euro Sham, with style
number L60910SHE2, is Pakistan.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request.? This position is 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.? If the facts are modified in any way, or if the goods do not conform to
these facts at the time of importation, you should bring this to the attention of 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 Title 19 of the Code of Federal Regulations
(19 C.F.R. Part 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, contact
National Import Specialist Seth Mazze at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division