OT:RR:NC:N2:350
Philip Lanitis
Lanitis & Associates Inc.
5422 County Road 862
McKinney, TX 75071
RE: Classification and country of origin determination for cotton artist canvas; 19 CFR 102.21(c)(1)
Dear Mr. Lanitis:
This is in reply to your letter dated April 22, 2025, requesting a classification and country of origin
determination for cotton artist canvas, which will be imported into the United States. Samples were submitted
to our office accompanying your request and will be retained for training purposes.
FACTS:
The subject merchandise is referred to as Styles 30-001, 30-002, 30-003, 30-004 and 30-005, described as
“Cotton Artist Canvas” intended to be used by artists for the making of paintings. All of the styles of the
cotton artist fabrics are constructed of a yarn dyed, woven textile fabric composed of 100 percent cotton
which is visibly coated on one surface with a plastic material composed of 50 percent acrylic, 12 percent
titanium dioxide and 38 percent filler resin. You state that all styles of the cotton artist fabrics will be
produced in full rolls measuring 60 inches and 54 inches in width and 50 yards in length.
You claim the manufacturing process for the canvas is as follows:
India
Fiber is formed.
Yarn is spun.
Yarn is dyed.
Fabric is woven.
Fabric is coated on one side.
Fabric is cut to size according to each style.
The finished fabric is packaged on roll and shipped in bags from India to the United States.
ISSUE:
What are the classification and country of origin of the subject merchandise?
CLASSIFICATION:
The applicable subheading for the Styles 30-001, 30-002, 30-003, 30-004 and 30-005, described as
“Cotton Artist Canvas” will be 5901.90.4000, Harmonized Tariff Schedule of the United States (“HTSUS”),
which provides for “Textile fabrics coated with gum or amylaceous substances, of a kind used for the outer
covers of books or the like; tracing cloth; prepared painting canvas; buckram and similar stiffened textile
fabrics of a kind used for hat foundations: Other; Other.” The general rate of duty will be 4.1 percent.
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withdrawn from warehouse, for consumption on or after July 1, 1996.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.
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 all of the Styles 30-001,
30-002, 30-003, 30-004 and 30-005, described as “Cotton Artist Canvas” are wholly obtained or produced in
a single country, that is, India, the country of origin is conferred in India.
HOLDING:
The classification of Styles 30-001, 30-002, 30-003, 30-004 and 30-005, described as “Cotton Artist Canvas”
is 5901.90.4000, HTSUS. The country of origin is India.
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. At this time products from all 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
5901.90.4000, HTSUS, listed above.
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 CFR 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 Michael Capanna at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division