OT:RR:NC:N2:349
Ms. Jennifer Zhan
Thorx Sdn. Bhd.
No.134 & 135, Jalan 4, Kawasan Perindustrian Olak Lempit Banting
Selangor 42700
Malaysia
RE: Classification and country of origin determination for automobile floor mats; 19 CFR 102.21(c)(2);
tariff shift
Dear Ms. Zhan:
This is in reply to your letter dated May 16, 2025, requesting a classification and country of origin
determination for automobile floor mats, which will be imported into the United States.
FACTS:
The subject merchandise, SKU# zt-0038SC-BK1SC-PUJD4NH22G#ML, is an automobile floor mat set
which includes two front mats and two rear mats. The mats are stated to be composed of 100 percent
polyester needle-loomed felt fabric backed with polyvinyl chloride (PVC) to create a non-skid surface. The
four mats feature 100 percent polypropylene woven binding along the edges and 2-inch-wide PVC faux
leather accents at the sides. The driver’s mat also includes a PVC faux leather heel cushion. The front mats
measure approximately 17 ¼ x 25 ½ inches and the rear mats measure approximately 12 × 17 ½ inches.
The manufacturing operations for the floor mats are as follows:
China
Polyester fibers are extruded, cut and dyed.
Dyed polyester staple fibers are carded to form a web.
Polyester felt fabric is formed by entangling the fibers using barbed needles.
Faux leather is formed.
Polypropylene binding is woven and dyed.
Polyester needle-loomed felt fabric, polyvinyl chloride (faux leather) and polypropylene binding are exported
to Malaysia.
Malaysia
PVC granules are formed.
Needle-loomed felt polyester fabric is laminated with PVC.
Laminated polyester needle-loomed felt fabric is cut to shape of mat.
Faux leather (PVC) is cut to shape.
Faux leather (PVC) heel pad is pressed on top of mat.
Faux leather (PVC) side accents are pressed and sewn on the mat.
Woven polypropylene binding is sewn around the edges of each mat.
Completed mat set is 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 the automobile mats will be 5704.90.0190, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Carpets and other textile floor coverings, of felt, not tufted or
flocked, whether or not made up: Other: Other.” The general rate of duty will be Free.
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 needle-loomed felt polyester fabric is lightweight and measures approximately 1/8 inch in thickness; it
lacks the stiffness, thickness, and strength of a textile floor covering on its own. As all of the components of
the automobile mats make the tariff shift in a single country, that is, Malaysia, as per the terms of the tariff
shift requirement, country of origin is conferred in Malaysia.
HOLDING:
The classification of the automobile mats, SKU# zt-0038SC-BK1SC-PUJD4NH22G#ML, is subheading
5704.90.0190, HTSUS. The country of origin of the automobile mats is Malaysia pursuant to 19 CFR
102.21(c)(2).
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
5704.90.0190, 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