OT:RR:NC:N3:351
Ms. Irene Yuan
Higher Technology (Cambodia) Co., Ltd
Land#189, Road 140, Bak Chenhchien Village, Trapeang Kong Commune, Samroang Tong District,
Kampong Speu Province.
Phnom Penh 050113
Cambodia
RE: The country of origin determination of a backseat car organizer; 19 CFR 102.21(c)(2)
Dear Ms. Yuan:
In your letter dated April 7, 2025, you requested a country of origin determination ruling. You previously
obtained a tariff classification and country of origin determination under NY Ruling N345782, dated
February 26, 2025, for a backseat car organizer. You state the only differences are the style number of the
item and the country where the fabric is sourced. A sample of the product was provided to this office for NY
Ruling N345782 and will be retained for training purposes.
Item B01G3303002.2, described as a “Car Seat Organizer,” is a textile over-the-seat car organizer. The flat,
rectangular shaped organizer consists of three panels. The top and bottom panel is composed of 100 percent
polyester woven printed oxford fabric with a water-resistant PVC coating on the front side and a visible PVC
coating only on the back side. The middle panel is composed of 100 percent polyester dyed (black) woven
oxford fabric with a water-resistant PVC coating on the front side and a visible PVC coating only on the back
side. The panels are joined together by a polyethylene (PE) cardboard strip sewn on top of the panels and the
organizer is finished with a 100 percent polypropylene woven binding. The completed organizer measures
23 inches in length by 18 inches in width. The front side of the organizer features three mesh open pockets
sewn on top of the middle panel. Each pocket, measuring 6 ½ inches in length by 6 ½ inches in width, is
composed of 100 percent polyester dyed (black) knit mesh fabric and finished with a 100 percent
polypropylene woven elastic binding on the top edge. The back side of the organizer features two adjustable
100 percent polypropylene woven webbing straps with a plastic formaldehyde buckle, allowing the user to
secure the item to the front seat of a car.
The fabric which comprises the three panels of the car seat organizer is said to have a water-resistant PVC
coating on the front side and a visible PVC coating only on the back side. Note 3 to Chapter 59 of the
Harmonized Tariff Schedule of the United States (HTSUS) states: For the purposes of heading 5903, “textile
fabrics coated with plastics” means products made by the assembly of one or more layers of fabrics with one
or more sheets or film of plastics which are combined by any process that bonds the layers together, whether
or not the sheets or film of plastics are visible to the naked eye in the cross-section. Based upon the
information received in your request, we find that the subject middle panel of the car seat organizer is
composed of textile fabric coated with plastics of heading 5903, HTSUS. Therefore, the completed car seat
organizer of coated fabrics will be considered a textile article of Section XI.
You state the manufacturing operations for the car seat organizer are as follows:
China:
• Polyester oxford yarn is formed and shipped to Cambodia.
Cambodia:
• Polyester oxford fabric is woven, dyed, printed, and coated with PVC on the back side.
• Polyester oxford fabric is woven, dyed, and coated with water-resistant PVC on both sides.
• Polyester mesh fabric is knitted and dyed.
• Polyester sewing thread, polypropylene woven binding, polypropylene woven elastic binding, and
polypropylene woven webbing strap, and polyethylene cardboard strip is formed.
• Plastic formaldehyde buckle is produced.
• Cutting and sewing of the fabric, binding, strap, and strip.
• The car seat organizer is packaged and shipped to the United States.
ISSUE:
What are the classification and country of origin of the subject merchandise?
CLASSIFICATION:
The applicable subheading for the car seat organizer will be 6307.90.9891, Harmonized Tariff Schedule of
the United States, (HTSUS), which provides for “Other made up articles, including dress patterns: Other:
Other: Other: Other: Other.” The rate of duty will be 7 percent ad valorem.
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 World Wide Web at https://hts.usitc.gov/current.
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) 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 6307.90 is the country,
territory, or insular possession in which the fabric comprising the good
was formed by a fabric-making process.
The car seat organizer is comprised of multiple panels of fabric sewn together, and each of these fabrics are
formed by a fabric-making process in a single country, that is Cambodia. Therefore, pursuant to 19 CFR
102.21(c)(2), the country of origin of the car seat organizer is Cambodia.
HOLDING:
The applicable subheading for the car seat organizer will be 6307.90.9891, HTSUS, and the country of origin
is Cambodia.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to
subheading 6307.90.9891, HTSUS, listed above.
The HTSUSA is subject to periodic amendment so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 Kristine Dodge at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division