OT:RR:NC:N2:349
Ms. Yaping Shan
Hangzhou Joyce Household Texitles Co.,Ltd.
No.2675 Xinluo Road, Xintang Street, Xiaoshan district
Hangzhou 311201
China
RE: Country of origin determination for a pillow protector and pillow insert; 19 CFR 102.21(c)(2); tariff
shift
Dear Ms. Shan:
This is in reply to your letter dated July 17, 2025, requesting a country of origin determination for a pillow
protector and a pillow insert which will be imported into the United States.
FACTS:
Item 1 is a pillow protector made of 100 percent cotton woven fabric that is dyed white. The pillow protector
features a zipper closure on one end and comes in standard and gusseted versions. The standard pillow
protectors are imported in sizes Standard (SKU# 11104G-STD-WHITE), Queen (SKU# 11104G-Q-WHITE),
King (SKU# 11104G-K-WHITE), Euro (SKU# 11104G-E-WHITE), and Toddler (SKU#
11106G-TODDLE-WHITE). The gusseted pillow protectors are imported in sizes Standard (SKU#
11223-STD-WHITE), King (11223-K-WHITE), and Euro (11223-E-WHITE).
Item 2, SKU# 11189-TODDLER-WHITE, is a down alternative toddler pillow insert. The pillow has an
outer shell of 100 percent cotton woven fabric that is dyed white and stuffed with 100 percent polyester
fiberfill. The edges are finished with a knife edge. The pillow measures 18 × 13 inches. The toddler pillow
insert and toddler pillow protector will be packaged and sold separately.
The manufacturing operations for the pillow protectors and pillow insert are as follows:
Pakistan:
Cotton shell fabric is woven.
Fabric is exported to China
China:
Fiberfill, zippers, labels and sewing thread are manufactured.
Cotton fabric is bleached and dyed white.
Cotton fabric is cut and assembled by sewing into a pillow shell and a pillow protector.
Pillow shell is filled with polyester fiber and sewn closed.
Zipper is sewn into end of pillow protector.
Finished pillow insert and pillow protector are exported to the United States.
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withdrawn from warehouse, for consumption on or after July 1, 1996.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:”
The pillow protectors are classified under subheading 6302.31, Harmonized Tariff Schedule of the United
States (HTSUS). The pillow is classified under subheading 9404.90.10, HTSUS. 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 a fabric-making
process.
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 “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 pillow protectors and pillow insert are not classified among the paragraph (e)(2) exceptions to the
above tariff shift rules. As the fabric for the pillow protectors and pillow inserts are 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 pillow protectors and pillow insert is Pakistan in accordance with 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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division