OT:RR:NC:N3:348
Kristin Young
Norman Krieger Inc
5000 East Spring Street Ste 250
Long Beach, CA 90815
RE: Classification and country of origin determination for an unfinished belt; 19 CFR 102.21(c)(5)); last
country where an important assembly or manufacturing process occurred
Dear Ms. Young:
This is in reply to your letter dated June 24, 2025, requesting a classification and country of origin
determination for unfinished belts on behalf of CFL Distribution, which will be imported into the United
States.
FACTS:
The subject merchandise consists of two unfinished unisex fashion belts. Styles SC135 and SC136 measure
approximately 59 inches in length and 1.5 inches in width. The strap, that encircles the waist, is constructed
from 100% polyester narrow woven fabric. The ratchet strap is constructed from 100% polyurethane
material. Style SC136 is ornamented with a woven polyester ribbon. The unfinished belts do not contain a
buckle at the time of importation.
The manufacturing operations are as follows:
Unfinished belt – Style SC135
The embroidered polyester woven fabric is manufactured and cut to length in China or in Cambodia.
The ratchet strap component is manufactured in Cambodia and sewn/attached to one end of the
embroidered polyester strap in Cambodia.
A buckle will be added after importation into the United States.
Unfinished belt – Style SC136
The polyester woven fabric and polyester ribbon are manufactured and cut to length in China or
Cambodia.
A ratchet strap is manufactured in Cambodia and sewn/attached to one end of the ornamented polyester
strap in Cambodia.
A buckle will be added after importation into the United States.
ISSUE:
What are the classification and country of origin of the subject merchandise?
CLASSIFICATION:
The applicable subheading for Styles SC135 and SC136 will be 6217.10.9530, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for Other made-up clothing accessories; parts of garments or
of clothing accessories, other than those of heading 6212: Accessories: Other: Other: Of man-made fibers.
The general rate of duty will be 14.6 percent ad valorem.
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withdrawn from warehouse, for consumption on or after July 1, 1996.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
6215-6217 (1) If the good consists of two or more component parts, a change to an
assembled good of heading 6215 through 6217 from unassembled
components, provided that the change is the result of the good being wholly
assembled in a single country, territory, or insular possession.
As the unfinished belt is not wholly assembled in a single country, territory or insular possession, Section
102.21(c)(2) is inapplicable.
Paragraph (c)(3) states, “Where the country of origin of a textile or apparel product cannot be determined
under paragraph (c) (1) or (2) of this section: if the good was knit to shape, the country of origin of the good
is the single country, territory, or insular possession in which the good was knit; or except for fabrics of
chapter 59 and goods of headings 5609, 5807, 5811, 6213, 6214, 6301 through 6306, and 6308, and
subheadings 6307.10, 6307.90, 9404.90, and 9619.00.31-33 if the good was not knit to shape and the good
was wholly assembled in a single country, territory, or insular possession, the country of origin of the good is
the country, territory, or insular possession in which the good was wholly assembled.”
As the subject merchandise is neither knit to shape, nor wholly assembled in a single country, Section 102.21
(c)(3) is inapplicable.
Paragraph (c)(4) states, “Where the country of origin of a textile or apparel product cannot be determined
under paragraph (c) (1), (2) or (3) of this section, the country of origin of the good is the single country,
territory, or insular possession in which the most important assembly or manufacturing process occurred.”
In the case of the subject merchandise, as the single country, territory, or insular possession in which the most
important assembly or manufacturing operation occurred cannot be determined, Section 102.21 (c)(4) is not
applicable.
Paragraph (c)(5) states, “Where the country of origin of a textile or apparel product cannot be determined
under paragraph (c) (1), (2), (3) or (4) of this section, the country of origin of the good is the last country,
territory, or insular possession in which an important assembly or manufacturing process occurred.”
Accordingly, in the case of the subject belts, the country of origin is conferred by the last country in which an
important assembly or manufacturing process occurred, that is, Cambodia.
HOLDING:
The country of origin of the unfinished belts is Cambodia.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries,
including Cambodia, will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry,
you must report the Chapter 99 heading applicable to your product classification, 9903.01.25, in addition to
subheading 6217.10.9530, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided
for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying
duty rates are provided at https://hts.usitc.gov/.
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 Rosemarie Hayward at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division