OT:RR:NC:N2:349
Margaret Polito, Attorney At Law
3401 SE Court Drive
Stuart, FL 34997
RE: Country of origin determination for a pillowcase; 19 CFR 102.21(c)(2); tariff shift
Dear Ms. Polito:
This is in reply to your letter dated May 30, 2025, requesting a country of origin determination on behalf of
your client, Pac-Fung Feather Co., Ltd., for a set of two pillowcases which will be imported into the United
States. In lieu of a sample, photographs were submitted along with your request.
FACTS:
The subject merchandise, Style # PC440L, consists of a set of two pillowcases constructed of 280 thread
count, 100 percent cotton plain woven fabric. Each pillowcase is dyed. They are neither printed nor napped.
The pillowcases consist of two panels sewn together on three sides. The fourth side is left open to allow for
the insertion of a pillow. The open end of the pillowcase has a 4-inch-wide self-fabric hem held with a row
of single needle stitching. The pillowcase does not contain any embroidery, lace, braid, edging, trimming,
piping, or applique. You state that the pillowcases will be produced in a standard size, 20 x 32 inches, and
king size, 20 x 40 inches.
The manufacturing operations for the pillowcase are as follows:
Vietnam
Greige plain woven cotton fabric is formed.
Greige plain woven cotton fabric is shipped in rolls to China.
China
Greige plain woven cotton fabric is de-sized, mercerized, bleached, dyed, calendared and preshrunk.
The finished fabric is cut into panels and sewn to produce a pillowcase.
The pillowcases are packaged in sets of two and exported to United States.
ISSUE:
What is 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withdrawn from warehouse, for consumption on or after July 1, 1996.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 pillowcase is classified under subheading 6302.31,
HTSUS, which is not included in the paragraph (e)(2) exception to the above tariff shift rule. Therefore, as
the fabric comprising the pillowcases is formed in a single country, that is, Vietnam, country of origin is
conferred in Vietnam.
HOLDING:
The country of origin of the pillowcase is Vietnam 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