OT:RR:NC:N2:349
Ms. Silvia Hall
All Strong
950 Raco Drive, Suite F
Lawrenceville, GA 30046
RE: Country of origin determination for a plush blanket; 19 CFR 102.21(c)(2); tariff shift
Dear Ms. Hall:
This is in reply to your letter dated June 22, 2025, requesting a country of origin determination for a plush
blanket, which will be imported into the United States. Photographs were provided in lieu of the sample.
FACTS:
The subject merchandise, “MS Plush Blanket,” is a plush blanket made from a single layer of 100 percent
polyester knit pile fabric. The fabric is either dyed or printed. All four edges are hemmed. The blanket will
be imported in the following sizes and colors: Twin 66” x 90”, Dyed Gray (Model #MSF500686322001);
Twin 66” x 90”, Dyed Indigo (Model #MSF500686322004); Twin 66” x 90”, Printed Neutral Plaid (Model
#MSF500686322007); Full/Queen 90” x 90”, Dyed Gray (Model # MSF5006863322002); Full/Queen 90” x
90”, Dyed Indigo (Model #MSF500686322005); Full/Queen 90” x 90”, Printed Neutral Plaid (Model
#MSF00686322008); King 102” x 90”, Dyed gray (Model #MSF500686322003); King 102” x 90”, Dyed
Indigo (Model #MSF500686322006); King 102” x 90”, Neutral Plaid (Model #MSF500686322009). You
state that the blanket may also be imported in sizes 50” x 60” and 50” x 72”, but you did not provide model
numbers for these sizes. The item will be imported and marketed under Mainstays™ and sold in Walmart
retail stores and Walmart.com.
The manufacturing operations for the plush blanket are as follows:
China
Plush fabric is knitted.
Plush fabric is dyed or printed.
Plush fabric is exported to Vietnam.
Vietnam
Plush fabric is brushed, polished and treated with an anti-pilling chemical.
Plush fabric is cut to size and hemmed.
Completed blanket is packaged and exported to the U.S.
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withdrawn from warehouse, for consumption on or after July 1, 1996.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 the fabric making
process.
The “fabric-making process” is defined in 19 CFR 102.21(b)(2) as “any manufacturing operation that begins
with polymers, fibers, filaments (including strips), yarns, twine, cordage, rope, or fabric strips and results in a
textile fabric.”
The subject blanket is classified under heading 6301, Harmonized Tariff Schedule of the United States, and
is, therefore, not included in the paragraph (e)(2) exception. As the fabric for the plush blanket is 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 “MS Plush Blanket” 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,
James Forkan
Acting Director
National Commodity Specialist Division