OT:RR:NC:N2:349
Ms. Irene Yuan
Higher Technology (Thailand) Co. Ltd.
999/5 Moo 4, U-thai Sub-district, U-thai District
Ayutthaya 13210
Thailand
RE: Country of origin determination for automobile mats; 19 CFR 102.21(c)(2); tariff shift
Dear Ms. Yuan:
This is in reply to your letter dated April 30, 2025, requesting a country of origin determination for
automobile floor mats which will be imported into the United States. A sample was not provided.
FACTS:
The subject merchandise consists of a set of four automobile floor mats, Item number 202WM38. You state
the mats are of woven polyester backed with polyvinyl chloride (PVC). The mats are finished with knit
polypropylene binding around the edges. The driver’s side floor mat includes a sewn on PVC heel pad. The
mats are available in multiple colors, including black, beige and gray.
The manufacturing operations for the automobile mats are as follows:
China
Polyester yarn spun.
Polyester yarn exported to Thailand.
Japan
PVC particles are made.
PVC particles are exported to Thailand.
Thailand
Polyester carpet fabric is woven.
Polypropylene binding is knit.
PVC particles are processed.
PVC particles are injected to form heel pad.
Carpet backing is laminated with PVC.
Laminated carpet is cut to size and shape.
Heel pad is sewn onto face of driver’s side floor mat.
Binding is sewn around the edge of the floor mats.
Floor mats are packaged and 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withdrawn from warehouse, for consumption on or after July 1, 1996.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
5701-5705 A change to heading 5701 through 5705 from any other chapter.
The automobile floor mats with an exposed surface of textile fabric are classified under chapter 57,
Harmonized Tariff Schedule of the United States. As all of the foreign materials incorporated in the floor
mats undergo an applicable change in tariff classification in a single country, that is, Thailand, as per the
terms of the tariff shift requirement, country of origin is conferred in Thailand.
HOLDING:
In accordance with 19 CFR 102.21(c)(2), the country of origin of the automobile floor mats is Thailand.
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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division