OT:RR:NC:N2:349
Richard Writsman
Continental Agency Inc
1768 W Second St
Pomona, CA 91766
RE: Country of origin determination for a fitted sheet; 19 CFR 102.21(c)(2); tariff shift
Dear Mr. Writsman:
This is in reply to your letter dated May 28, 2025, requesting a country of origin determination on behalf of
your client, Coop Home Goods LLC, for a fitted sheet, which will be imported into the United States.
FACTS:
The subject merchandise, FSM - Fitted Sheet Spa, consists of a fitted sheet designed to fit a massage table.
The fitted sheet is constructed of 100 percent polyester woven fabric and has an elasticized edge. The
elasticized edge is formed by inserting into the hem a narrow fabric, approximately 1.5 centimeters wide,
made from rubber thread covered in polyester yarn. The fitted sheet measures 30.25 X 73 X 5.75 inches.
The manufacturing operations for the fitted sheet are as follows:
China
Polyester fabric is woven.
Narrow elasticized fabric is formed.
Sewing thread is formed.
All materials are exported to Vietnam.
Vietnam
Fabric is cut to size and shape.
Fabric components are hemmed with an elasticized edge.
Completed fitted sheet is 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withdrawn from warehouse, for consumption on or after July 1, 1996.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
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 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.
Based on the information provided in your letter, the fitted sheet, FSM-Fitted Sheet SPA, is classified under
6302.32, Harmonized Tariff Schedule of the United States (HTSUS). The subheading is not included in the
paragraph (e)(2) exception to the above tariff rule.
As the polyester woven fabric and the elasticized fabric are formed in a single country, that is, China, as per
the terms of the tariff shift requirement, country of origin is conferred in China.
HOLDING:
The country of origin of the fitted sheet, FSM-Fitted Sheet SPA, is China, pursuant to 19 CFR 102.21(c)(2).
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