CLA-2-94:OT:RR:NC:N2:349
Mr. Zijie Guo
Pioneer & Legend Canada Ltd.
310 Vaughan Valley Blvd, Unit 1
Vaughan L4H3C3
Canada
RE: The eligibility under the United States-Mexico-Canada Agreement (USMCA) of pocket coil mattress
core units from Canada
Dear Mr. Guo:
In your letter dated May 27, 2025, you requested a binding ruling on the eligibility of pocket coil mattress
core units under the United States-Mexico-Canada Agreement (USMCA). In your request, you provided a
description of the finished article and its materials including the origin of the components.
FACTS:
The subject merchandise is a pocket coil mattress core unit composed of steel wire springs individually
encased in nonwoven fabric strips, arranged and glued in rows, and covered on the top and bottom with a
sheet of nonwoven fabric which is bonded to the coils with glue. The core unit provides the structural layer
of a completed mattress. The core units are sized for Twin, Twin-XL, Double, Queen, King and California
King mattresses.
The manufacturing operations for the pocket coil mattress core units are as follows:
Malaysia
Coils are formed from steel wire sourced from Malaysia or China.
Coils are loaded into polypropylene nonwoven fabric pocket strips.
Pocket coil strips are exported to Canada.
U.S. or Mexico
Glue is manufactured. (U.S. only)
Steel wire is manufactured.
Steel wire and glue are exported to Canada.
China
Nonwoven fabric forming the coil pockets and the top and bottom covering is formed.
Nonwoven fabric is exported to Malaysia and Canada.
Canada
Pocket coil strip that forms the perimeter of the mattress core unit is manufactured.
Pocket coil strip from Malaysia and Canada are cut to various lengths and glued row by row to the
appropriate size for the mattress. (The pocket coils formed in Malaysia make up the center of the unit
and the pocket coils formed in Canada make up the perimeter.)
Cut pocket coils are glued to nonwoven fabric on the top and bottom.
Pocket coil units are trimmed, shaped, inspected, and compressed.
Pocket coil units are shipped to the United States in compressed rolls.
Per your request, the materials used to produce the pocket coil mattress core and the associated Harmonized
Tariff Schedule of the United States (HTSUS) heading are: 1) pocket coil strips of heading 7326, HTSUS,
from Malaysia; 2) steel wire of heading 7217, HTSUS, from the U.S. or Mexico; 3) nonwoven fabric of
heading 5603, HTSUS, from China and 4) glue of heading 3506, HTSUS, from the U.S.
USMCA:
The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30,
2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the
USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN")
11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is
an originating good for purposes of the USMCA. GN 11(b) states:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential
tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the
tariff schedule as a "good originating in the territory of a USMCA country" only if-
(i) the good is a good wholly obtained or produced entirely in the territory of one or more
USMCA countries;
(ii) the good is a good produced entirely in the territory of one or more USMCA countries,
exclusively from originating materials;
(iii) the good is a good produced entirely in the territory of one or more USMCA countries
using non-originating materials, if the good satisfies all applicable requirements set forth in
this note (including the provisions of subdivision (o));
Since the pocket coil mattress core contains non-originating materials, they are not considered a good wholly
obtained or produced entirely in a USMCA country under GN 11(b)(i), nor are the products produced
exclusively from originating materials per GN 11(b)(ii). Thus, we must determine whether the product
qualifies under GN 11(b)(iii). The pocket coil mattress core units are classified under subheading
9404.29.90, HTSUS. The applicable rule of origin for goods classified under subheading 9404.29.90,
HTSUS, is in GN 11(o)/ 94.6, HTSUS, which provides “[a] change to subheadings 9404.10 through 9404.90
from any other chapter.”
Based on the facts provided, the goods described above qualify for USMCA preferential tariff treatment,
because they will meet the requirements of General Note 11(b)(iii) since all components and materials
undergo the prescribed tariff shift. The goods will, therefore, be entitled to a free rate of duty under the
USMCA upon compliance with all applicable laws, regulations, and agreements.
HOLDING:
The pocket coil mattress core units, described above, qualify for USMCA upon compliance with all
applicable laws, regulations, and agreements.
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