OT:RR:NC:N2:349
Ms. Selina Xu
Aquastar Inc. DBA Concept Manufacturing
13417 Benson Ave.
Chino, CA 91710
RE: Country of origin determination for disposable microfiber mop pads; 19 CFR 102.21(c)(2); tariff shift
Dear Ms. Xu:
This is in reply to your letter dated June 20, 2025, requesting a country of origin determination for disposable
microfiber mop pads, which will be imported into the United States. Photographs were provided in lieu of
the sample.
FACTS:
The subject merchandise, item# 92053, described as “Mop Head Microfiber Compressed Packing,” consists
of a 288-piece pack of disposable microfiber cleaning mop pads used for dry or wet mop cleaning to sweep
dirt, dust, pet hair and other small and large particles from floors. The cleaning mop pad consists of three
layers. The face fabric is comprised of 100 percent polyester woven pile fabric and is the primary fabric
designed to trap dirt, dust, debris and absorb water. A narrow strip of 100 percent polyester needle punched
nonwoven fabric is sewn on center onto the face fabric the full length of the mop pad; its role is to reduce the
friction of the mop head. The backing fabric is composed of 100 percent polyester oxford woven fabric. The
ends of the backing fabric are folded over 5.5 to 6 centimeters toward the center and sewn down to the top
and bottom edges creating a pocket at each end of the pad to facilitate its attachment to the mop’s frame. The
rectangular shaped cleaning pad measures approximately 16 inches in length by 5 ¾ inches in width. You
state the cleaning pads are not designed for a specific mop. The bulk packs are sold to Medline Inc.
The manufacturing operations for the “Mop Head Microfiber Compressed Packing”, item# 92053, are as
follows:
China:
Polyester woven pile (face) fabric is formed.
Needle punched polyester nonwoven (center face) fabric is formed.
Polyester oxford woven (backing) fabric is formed.
The three fabrics are slit into specified widths.
Fabrics are assembled by bonding with ultrasonic welding and sewing.
An overlock stitch is sewn along the long sides.
Fabrics shipped in rolls to Vietnam.
Vietnam:
Assembled fabrics are cut to specified length.
An overlock stitch is sewn along the short sides.
Excess sewing thread is removed, and mop pad is trimmed.
Quality inspection is conducted.
Finished mop pads are placed in polybags, compressed and placed in corrugated boxes.
Finished mop pads are shipped 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:”
The “Mop Head Microfiber Compressed Packing” is classified under Subheading 6307.10, Harmonized
Tariff Schedule of the United States (HTSUS). 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
6307.10 The country of origin of a good classifiable under subheading 6307.10 is the
country, territory, or insular possession in which the fabric comprising the
good is 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.
As the three fabrics for the microfiber cleaning mop pad are formed by the fabric making process 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 “Mop Head Microfiber Compressed Packing,” item# 92053, is China pursuant
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,
James Forkan
Acting Director
National Commodity Specialist Division