OT:RR:NC:N2:349
Mr. Ping Gao
E&E Co. Ltd.
45875 Northport Loop East, Building B
Fremont, CA 94587
RE: Classification and country of origin determination for quilted blanket; 19 CFR 102.13; De Minimis; 19
CFR 102.21(c)(5); last country where an important assembly or manufacturing process occurred
Dear Mr. Gao:
This is in reply to your letter dated May 20, 2025, requesting a classification and country of origin
determination for a quilted blanket, which will be imported into the United States. A sample of the quilted
blanket was submitted with your request and will be retained by this office for training purposes.
FACTS:
The subject merchandise, “Cooling Touch Down Alternative Throw,” is a quilted blanket comprised of three
layers: two fabrics and fiberfill. The face side is composed of 77 percent nylon and 23 percent polyethylene,
dyed, knitted fabric and the reverse side is composed of 100 percent polyester, dyed, woven fabric. Polyester
fiberfill is stuffed between the two fabrics. The three layers are quilted together in a wavy block pattern. The
blanket measures 50 x 60 inches and is finished along the edges with 100 percent polyester brushed knit
binding. It will be packaged and imported for retail sale with a single ribbon with hook and loop tabs. You
state that the item is intended for indoor use to provide warmth to an individual.
The manufacturing operations for the quilted blanket are as follows:
China
Nylon/polyethylene face fabric is knitted and dyed.
Knitted nylon/polyethylene face fabric is shipped in rolls to Pakistan.
Pakistan
Polyester backing fabric is woven and dyed.
Polyester fiberfill material is formed.
Polyester brushed knit binding is formed.
Fabrics are cut, assembled by sewing, filled and quilted.
Finished quilted blankets are exported to the United States.
ISSUE:
What are the classification and country of origin of the subject merchandise?
CLASSIFICATION:
The applicable subheading for “Cooling Touch Down Alternative Throw” will be 6301.40.0020, HTSUS,
which provides for 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 the fabric-making
process.
The “fabric-making process” is defined in 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.
The quilted blanket is made from three fabrics formed in two different countries. The face fabric is formed in
China and the backing and binding fabrics are formed in Pakistan; however, the binding fabric is disregarded
in accordance with Section 102.13, the De Minimis rule.
Section 102.21(c), "General Rules," inter alia, states the requirements or conditions of Sections 102.12
through 102.19, where appropriate, are applicable when determining origin under Section 102.21(c)(1)
through (5). Section 102.13 "De Minimis," states the following, in pertinent part:
(c) Foreign components or materials that do not undergo the applicable change in tariff classification
set out in Section 102.21 or satisfy the other applicable requirements of that section when
incorporated into a textile or apparel product covered by that Section shall be disregarded in
determining the country of origin of the good if the total weight of those components or materials is
not more than 7 percent of the total weight of the good.
With respect to the quilted blanket, you state the binding fabric represents .60 percent of the total weight.
Consequently, the binding fabric is disregarded when determining the country of origin of the quilted
blanket. However, as the face and backing fabrics 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 goods of heading 5609, 5807, 5811, 6213, 6214, 6301 through 6306, and 6308, and
subheadings 6209.20.5040, 6307.10, 6307.90, and 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 quilted blanket, the country of origin is conferred by the last country
in which an important assembly or manufacturing process occurred, that is, Pakistan.
HOLDING:
The applicable subheading for the “Cooling Touch Down Alternative Throw” is under subheading
6301.40.0020, HTSUS, and the country of origin is Pakistan pursuant to 19 CFR 102.21(c)(5).
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 for country-of-origin Pakistan,
in addition to subheading 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