OT:RR:NC:N2:349
Ms. Deana Smith
The William Carter Company
3438 Peachtree Rd, Suite 1800
Atlanta, GA 30326
RE: Country of origin determination for an infant’s blanket; 19 CFR 102.21(c)(5)); last country where an
important assembly or manufacturing process occurred
Dear Ms. Smith:
This is in reply to your letter dated April 8, 2025, requesting a country of origin and marking determination
for an infant’s faux fur blanket, which will be imported into the United States. A sample was provided and
will be returned to you as requested.
FACTS:
The subject merchandise consists of an infant’s 2-ply blanket. The front/face side of the blanket is made
from 100 percent polyester knit pile fabric. The back side is made from 100 percent polyester jersey knit
fabric. Both fabrics are dyed pink. The two layers are joined and a satin binding is sewn along the four edges
creating a 1 ½ inch border. The blanket measures 40 × 30 inches. The blanket is designed for protection
against the cold.
The manufacturing operations for the blanket are as follows:
Indonesia
Fabric front/face side made of 100 percent polyester pile fabric is knit, dyed and finished.
Fabric is shipped in rolls to Vietnam.
Vietnam
Fabric back side made of 100 percent polyester jersey knit fabric is knit, dyed and finished.
Binding fabric made of 100 percent polyester is woven, dyed and finished.
Fabrics are cut and sewn into blanket.
Finished blanket is exported 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withdrawn from warehouse, for consumption on or after July 1, 1996.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) 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
6301 - 6306 Except for goods of heading 6302 through 6304 provided for in paragraph
(e)(2) of this section, the country of origin of a good classifiable under
heading 6301 through 6306 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.”
The blanket is classified under heading 6301, Harmonized Tariff Schedule of the United States (HTSUS). As
the fabrics comprising the blanket are not formed in a single country, Section 102.21(c)(2) is inapplicable.
Paragraph (c)(3) 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.” As the subject
merchandise is not knit to shape, and is excepted from paragraph (ii), Section 102.21 (c)(3) is inapplicable.
Paragraph (c)(4) 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
the case of the subject merchandise, the most important manufacturing process occurs at the time of fabric
making. ?The fabrics for the instant item are sourced in more than one country. ?As no one fabric is more
important than the other, a single country of origin determination cannot be made based on Section
102.21(c)(4). ?
Paragraph (c)(5) states, ?Where the country of origin of a textile or apparel product cannot be determined
under paragraph (c) (1), (2), (3) or (4) of this section, the country of origin of the good is the last country,
territory, or insular possession in which an important assembly or manufacturing process occurred.??
Accordingly, in the case of the subject blanket, the country of origin is conferred by the last country in which
an important assembly or manufacturing process occurred, that is, Vietnam.
HOLDING:
The country of origin of the infant?s blanket is Vietnam.
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,
Steven A. Mack
Director
National Commodity Specialist Division