OT:RR:NC:N2:349
Ms. Jane Liu
Yantai North Home Textile Co., Ltd
No.66 Jinfeng Road, Yantai
Yantai 265500
China
RE: Country of origin determination for sheets, duvet cover, and pillowcases; 19 CFR 102.21(c)(2); tariff
shift
Dear Ms. Liu:
This is in reply to your letter dated June 10, 2025, requesting a country of origin determination for a duvet
cover, sheets, and pillowcases. Photographs were provided in lieu of a sample.
FACTS:
The subject merchandise, described as “Blossom Trail Percale Green Tea,” includes a flat sheet, Item #
51429A; fitted sheet, Item # 51429B; pillowcases, Item # 51429C; and a duvet cover, Item # 51429D. All of
the items are composed of 100 percent cotton woven fabric that is both dyed and printed with a botanical
print design of stems and flowers. You state the fabric is not napped and that the completed articles do not
contain any embroidery, lace, braid, edging, trimming, piping or applique work. The flat sheet is hemmed
around the edges with a four-inch hem at the top. The fitted sheet is hemmed with fully elasticized edges.
The pillowcases are folded at one end with an opening at the other and are sewn on the top and bottom. The
open end of the pillowcase features a 4-inch-wide hem. The pillowcases are offered in Standard (20” x 30”)
and King (20” x 40”). The duvet cover features an opening at one end with button closures and knife edges.
The duvet cover does not include a stuffed duvet. The sheets and duvet are offered in Twin, Full, Queen and
King sizes. The items will be sold separately at retail and, also, offered as a 3-piece or 4-piece sheet set under
Item # 51429L which consists of 1 flat sheet, 1 fitted sheet and 1 or 2 pcs of pillowcases. You also state that
this product will be offered in additional printed pattern designs and in solid colors and that the Item # will be
determined, accordingly.
The manufacturing operations for the sheets, duvet cover, and pillowcases, item # 51429(A-D), are as
follows:
Pakistan
Cotton greige fabric is woven.
Cotton griege fabric is shipped in rolls to China.
China
Cotton fabric is bleached, dyed, printed and shrunk.
Elastic band, buttons and sewing thread are produced.
Fabric is cut, assembled and sewn into finished flat sheets, fitted sheets, duvet covers and pillowcases.
Finished sheets, duvet covers and pillowcases are packaged and shipped to United States.
ISSUE:
What 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)(1) provides the rules used to determine the country of origin of a textile or apparel product
under paragraph (c)(2) of this section. The sheets, duvet covers and pillowcases are classified under
subheading 6302.21, Harmonized Tariff Schedule of the United States (HTSUS), if printed, and under
subheading 6302.31, HTSUS, if not printed.
Paragraph (e)(1), 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.
Subheadings 6302.21 and 6302.31, HTSUS, are not included in the paragraph (e)(2) exception to the above
tariff shift rule. Therefore, as the fabrics comprising the sheets, duvet covers and pillowcases are formed in a
single country, which is, Pakistan, the country of origin is conferred in Pakistan.
HOLDING:
Pursuant 102.21(c)(2), the country of origin of the sheets, duvet covers, and pillowcases are Pakistan.
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,
James Forkan
Acting Director
National Commodity Specialist Division