OT:RR:NC:N2:349
Ms. Penny Zhang
ABS International Inc.
5 Floor, No.2000 Pudong Avenue
Shanghai 200135
China
RE: Classification and country of origin determination for blankets; 19 CFR 102.21(c)(2); tariff shift
Dear Ms. Zhang:
This is in reply to your letter dated May 8, 2025, requesting a classification and country of origin
determination for blankets which will be imported into the United States. Samples of item # ABS2505001
and item # ABS2505002 were provided and will be retained by this office. You subsequently added item #
ABS2505003 to your request and provided photographs in lieu of a sample.
FACTS:
Item # ABS2505001 is a grey and white knitted blanket of 100 percent polyester yarns. You state that the
blanket is formed from rib knit stitches though the fabric appears to have a brioche knit structure. The knit to
shape blanket measures approximately 120 × 105 inches.
Item # ABS2505002 which you refer to as a woven throw is a blanket of 100 percent polyester chenille
yarns. The white and blue blanket is woven in a plaid pattern and features knotted fringe at the ends of the
warp. After weaving, no further working is required other than cutting across the sections of warp yarns that
appear without weft yarns and knotting the fringe. The blanket measures approximately 50 × 60 inches.
Item # ABS2505003 is a 100 percent polyester printed knit fleece blanket. You state the edges are hemmed
with a cover stitch. The blanket measures 60 × 70 inches.
All three items are considered to be blankets for classification purposes due to the texture of the material
which is designed to provide protection against the cold.
The manufacturing operations for item # ABS2505001 are as follows:
China
Polyester yarns are produced and dyed.
The dyed yarns are exported to Vietnam.
Vietnam
The blanket is knit to shape.
Label is sewn on blanket.
Blanket is packaged and exported to the United States.
The manufacturing operations for item # ABS2505002 are as follows:
Scenario 1
China
Polyester yarns are produced and dyed.
Polyester fabric is woven with sections containing warp yarns without weft yarns.
Polyester fabric is exported to Thailand in rolls.
Thailand
Polyester fabric is cut from rolls where warp yarns appear without weft yarns.
Extended warp yarns are knotted to create fringe.
Label is sewn on blanket.
Blanket is packaged and exported to the United States.
Scenario 2
China
Polyester yarns are produced and dyed.
The dyed yarns are exported to Vietnam.
Vietnam
Polyester fabric is woven with sections containing warp yarns without weft yarns.
Polyester fabric is cut from rolls where warp yarns appear without weft yarns.
Extended warp yarns are knotted to create fringe.
Label is sewn on blanket.
Blanket is packaged and exported to the United States.
The manufacturing operations for item # ABS2505003 are as follows:
China
Polyester yarns are produced.
Polyester fleece fabric is knitted and printed.
Printed polyester fleece fabric is exported to Thailand.
Thailand
Printed polyester fleece fabric is cut and sewn to create blanket.
Blankets are packaged and exported to the United States.
ISSUE:
What are the classification and country of origin of the subject merchandise?
CLASSIFICATION:
The applicable subheading for Item # ABS2505002 will be 6301.40.0010, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Blankets and traveling rugs: Blankets (other than electric
blankets) and traveling rugs, of synthetic fibers: Woven.” The general rate of duty will be 8.5 percent ad
valorem.
The applicable subheading for Items # ABS2505001 and # ABS2505003 will be 6301.40.0020, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for Blankets and traveling rugs: Blankets
(other than electric blankets) and traveling rugs, of synthetic fibers: Other.” The general rate of duty will be
8.5 percent ad valorem.
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 section 102.21(b)(2) as follows:
A fabric-making process is any manufacturing operation that begins with polymers, fibers, filaments
(including strips), yarns, twine, cordage, rope, or fabric strips and results in a textile fabric.
For item # ABS2505001, as the fabric-making process occurs in a single country, that is, Vietnam , as per the
terms of the tariff shift requirement, country of origin is conferred in Vietnam.
For item # ABS2505002, as the fabric-making process occurs in a single country, as per the terms of the tariff
shift requirement, country of origin is conferred in China under scenario 1 and Vietnam under scenario 2.
For item # ABS2505003, as the fabric-making process occurs in a single country, as per the terms of the tariff
shift requirement, country of origin is conferred in China.
HOLDING:
Item # ABS2505001 is classified under subheading 6301.40.0020, HTSUS. The country of origin is Vietnam
pursuant to 19 CFR 102.21(c)(2).
Item # ABS2505002 is classified under subheading 6301.40.0010, HTSUS. The country of origin is China
under scenario 1 and Vietnam under scenario 2 pursuant to 19 CFR 102.21(c)(2).
Item # ABS2505003 is classified under subheading 6301.40.0020, HTSUS. The country of origin is China
pursuant to 19 CFR 102.21(c)(2).
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheadings 6301.40.0010 and 6301.40.0020, HTSUS, listed above.
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 subheadings
6301.40.0010 and 6301.40.0020, 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 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