OT:RR:NC:N2:349
Ms. Yaping Shan
Hangzhou Joyce Household Textiles Co.,Ltd.
No.2675 Xinluo Road, Xintang Street, Xiaoshan District,
Hangzhou 311201
China
RE: Country of origin determination for a mattress topper; 19 CFR 102.21(c)(2); tariff shift
Dear Ms. Shan:
This is in reply to your letter dated June 24, 2025, requesting a country of origin determination for a mattress
topper, which will be imported into the United States. In lieu of a sample, pictures and a product description
were provided.
FACTS:
The subject mattress topper is comprised of a shell of 100 percent cotton woven fabric and is stuffed with
100 percent polyester fiber. The mattress topper has a four-inch gusset and self-fabric corded piping not
exceeding 6.35 millimeters on the edges. The mattress topper is available in the following sizes and SKUs:
Name SKU Product number Dimensions
LH DOWN ALT MATTRESS TOPPER 11204A-T-White 25MPAT01 39" x 75" x 4"
TWIN WHITE
LH DOWN ALT MATTRESS TOPPER 11204A-TXL-White 25MPATXL02 54" x 75" x 4"
FULL WHITE
LH DOWN ALT MATTRESS TOPPER 11204A-F-White 25MPAF03 60" x 80" x 4"
QUEEN WHITE
LH DOWN ALT MATTRESS TOPPER 11204A-Q-White 25MPAQ04 70" x 80" x 4"
KING WHITE
LH DOWN ALT MATTRESS TOPPER 11204A-K-White 25MPAK05 72" x 84" x 4"
CAL KING WHITE
The manufacturing operations are as follows:
PAKISTAN
The cotton shell fabric is woven.
The fabric is exported to China.
CHINA
The shell fabric is bleached and dyed.
The fabric is cut and assembled by sewing into an unfinished shell.
Polyester staple fiber is manufactured.
The shell is filled with polyester fiber and sewn closed.
The finished mattress topper is packaged and exported to the United States.
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withdrawn from warehouse, for consumption on or after July 1, 1996.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 does not apply.
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 mattress toppers are classified under subheading 9404.90.81, 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
9404.90 Except for goods of subheading 9404.90 provided for in paragraph
(e)(2) of this section, the country of origin of a good classifiable
under subheading 9404.90 is the country, territory, or insular
possession in which the fabric comprising the good was formed by
a fabric-making process.
The subject mattress toppers are not classified among the paragraph (e)(2) exceptions to the above tariff shift
rule. Therefore, as the fabric comprising the mattress topper is formed by the fabric-making process in a
single country, that is, Pakistan, as per the terms of the tariff shift requirement, country of origin is conferred
in Pakistan.
HOLDING:
The country of origin of the subject mattress toppers is Pakistan 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 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. If the facts are modified in any way, or if the goods do not conform to
these facts at the time of importation, you should bring this to the attention of 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 Title 19 of the Code of Federal Regulations
(19 CFR Part 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, contact
National Import Specialist Kim Wachtel at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division