OT:RR:NC:N3:351
Mr. Adam Eimers
Big Agnes, Inc
840 Yampa Street
Steamboat Springs, CO 80487
RE: The tariff classification and country of origin determination for tents and mesh insert; 19 CFR 102.21
(c)(2); 19 CFR 102.21(c)(5)
Dear Mr. Eimers:
This is in reply to your letter dated August 13, 2025, requesting a country of origin determination for four
tents and a mesh insert. In lieu of samples, photographs of the tents and mesh insert were provided with your
request.
SKU# TBH425, described as a “Big House 4,” is a 4-person outdoor folding tent with a backpack. The tent
is composed of manmade textile materials. The tent has a net weight of 12.65 pounds, a floor area of 57
square feet, and a standing height of 70 inches. The tent is imported together with a backpack that houses the
tent, rainfly, poles, and stakes. The backpack dimensions are 26 inches in length by 16 inches in width by 7
inches in height.
SKU# TBH625, described as a “Big House 6,” is a 6-person outdoor folding tent with a backpack. The tent
is composed of manmade textile materials. The tent has a net weight of 16.34 pounds, a floor area of 89
square feet, and a standing height of 80 inches. The tent is imported together with a backpack that houses the
tent, rainfly, poles, and stakes. The backpack dimensions are 26 inches in length by 16 ½ inches in width by
8 inches in height.
SKU# TBUNK425, described as a “Bunk House 4,” is a 4-person outdoor folding tent with a backpack. The
tent is composed of manmade textile materials. The tent has a net weight of 15.01 pounds, a floor area of 58
square feet, and a standing height of 72 inches. The tent is imported together with a backpack that houses the
tent, rainfly, poles, and stakes. The backpack dimensions are 26 ½ inches in length by 16 ½ inches in width
by 6 inches in height.
SKU# TBUNK625, described as a “Bunk House 6,” is a 6-person outdoor folding tent with a backpack. The
tent is composed of manmade textile materials. The tent has a net weight of 18.59 pounds, a floor area of 82
square feet, and a standing height of 78 inches. The tent is imported together with a backpack that houses the
tent, rainfly, poles, and stakes. The backpack dimensions are 27 ½ inches in length by 17 inches in width by
7 ½ inches in height.
SKU# TMESHSCSP25, described as an “Accessory Mesh Insert Sage Canyon Shelter Plus,” is a floorless
outdoor mesh insert designed to be used with the Sage Canyon Shelter for bug protection. The mesh insert
connects to the shelter by gear loops and features two zippered openings. The insert is composed of
manmade textile materials. The mesh insert has a net weight of 4.52 pounds, a floor area of 90 square feet,
and a standing height of 82 inches. The mesh insert is imported with a stuff sack that houses the mesh insert
and stakes. The mesh insert does not come with poles. The stuff sack measures 7 inches in length by 7
inches in width by 22 inches in height.
You state the pertinent manufacturing operations for the “Big House 4,” “Big House 6,” “Bunk House 4,”
“Bunk House 6,” tents and “Sage Canyon Mesh Insert” are as follows:
China:
• Big House 4 and Big House 6 -
o Backpack, rainfly, floor, and tent body, binding, loop, and corner fabric: 100 percent polyester
fabric is woven, dyed, and coated with waterproof polyurethane (PU) on one side and shipped in rolls
to Vietnam.
o Zippers, sliders, eyelets, printed tape, aluminum poles, and aluminum stakes are produced and
shipped to Vietnam.
• Bunk House 4 and Bunk House 6 –
o Floor, corner, binding, rainfly, and backpack fabric: 100 percent polyester fabric is woven, dyed,
and coated with PU and shipped in rolls to Vietnam.
o Body fabric: 100 percent polyester fabric is woven, dyed, and shipped in rolls to Vietnam.
o Zippers, sliders, eyelets, printed tape, aluminum poles, and aluminum stakes are produced and
shipped to Vietnam.
• Sage Canyon Mesh Insert –
o Bottom body fabric, stuff sack, and stake bag: 100 percent polyester fabric is woven, dyed, coated
with polyurethane (PU), and shipped in rolls to Vietnam.
o Zipper, slider, and aluminum stakes are produced and shipped to Vietnam.
Korea:
• Big House 4 and Big House 6 –
o Door and Roof Mesh Fabric: 100 percent nylon fabric is woven, dyed and shipped in rolls to
Vietnam.
o Clip, hook, buckles, PVC square toggle, PVC O-ring, and lion lock are produced and shipped to
Vietnam.
• Bunk House 4 and Bunk House 6 –
o Mesh Fabric: 100 percent nylon fabric is woven, dyed, and shipped in rolls to Vietnam.
o Lite tent hook, PVC ball cap, buckle, PVC square toggle, and PVC O-ring, lion lock, are produced
and shipped to Vietnam.
• Sage Canyon Mesh Insert –
o Mesh Fabric: 100 percent nylon fabric is woven, dyed, and shipped in rolls to Vietnam.
o PVC square toggle and cord lock ellipse are produced and shipped to Vietnam.
Taiwan:
• Big House 4, Big House 6, Bunk House 4, and Bunk House 6 –
o Seam tape is produced and shipped to Vietnam.
The United Kingdom:
• Big House 4, Big House 6, Bunk House 4, and Bunk House 6 –
o Clam Cleat is produced and shipped to Vietnam.
The United States:
• Big House 4, Big House 6, Bunk House 4, and Bunk House 6
o Seam tape is produced and shipped to Vietnam.
Vietnam:
• Big House 4 and Big House 6 –
o Webbing, Velcro, polyester string, thread, 10mm reflective, and E-band are produced.
o Fabric is cut to shape and size.
o Fabric is sewn and hemmed to create a tent, rainfly, and backpack.
o The tent, rainfly, poles, and stakes are placed in the backpack.
o The backpacks are packaged in cartons and shipped to the United States.
• Bunk House 4 and Bunk House 6 –
o Webbing, polyester string, thread, webbing, 10mm reflective, Velcro, and E-band are produced.
o Fabric is cut to shape and size.
o Fabric is sewn and hemmed to create a tent, rainfly, and backpack.
o The tent, rainfly, poles, and stakes are placed in the backpack.
o The backpacks are packaged in cartons and shipped to the United States.
• Sage Canyon Mesh Insert
o Webbing, polyester string, thread, and cord lock ellipse are produced.
o Fabric is cut to shape and size.
o Fabric is sewn and hemmed to create a mesh insert, stuff sack, and stake bag.
o The stakes are placed into a stake bag.
o All components are placed in the stuff sack.
o The mesh inserts are packaged in cartons and shipped to the United States.
ISSUES:
What is the country of origin for the imported tents and mesh insert?
CLASSIFICATION:
You have suggested that the Big House 4, Big House 6, Bunk House 4, and Bunk House 6 style tent should
be classified under subheading 6306.22, Harmonized Tariff Schedule of the United States (HTSUS), which
provides for “Tarpaulins, awnings and sunblinds; tents (including temporary canopies and similar articles);
sails for boats, sailboards or landcraft; camping goods: Tents (including temporary canopies and similar
articles): Of synthetic fibers.” We agree.
You have also suggested that the Sage Canyon Mesh Insert should be classified under subheading,
6307.90.9891, HTSUS, which provides for “Other made up articles, including dress pattern: Other: Other:
Other: Other: Other.” We agree.
It is the opinion of this office that the tent and the backpack as well as the mesh insert and stuff sack together
form a "composite good.”
The classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in
accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that
classification shall be determined according to the terms of the headings and any relative section or chapter
notes. Since no one heading in the tariff schedule covers the textile backpack and the tent or the textile stuff
sack and the mesh insert in combination, GRI 1 cannot be used as a basis for classification. GRI 3(b)
provides that mixtures, composite goods consisting of different materials or made up of different
components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or
component which gives them their essential character. In determining the essential character various factors
may be used to determine the component which imparts the essential character to the composite article. It is
the tents, and the mesh insert that are the main components that are necessary when the user is camping
outdoors. The tent is the component that provides shelter. The mesh insert when used with the Sage Canyon
Shelter provides bug protection. The backpack and stuff sack are specially designed to hold, store, and
transport the tent and mesh insert. Therefore, in accordance with GRI 3(b), it is the opinion of this office that
the tent and mesh insert impart the essential character and thus determines the classification. Accordingly,
the backpack is classified with the subject tents under subheading 6306.22, HTSUS, and the stuff sack is
classified with the mesh insert under subheading 6307.90.9891, HTSUS.
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 textile and apparel products entered, or withdrawn from
warehouse for consumption on and after July 1, 1996. Section 334 of the URAA was amended by section
405 of title IV of the Trade and Development Act of 2000, Public Law 106-200, 114 Stat. 251. Section
102.21 of Title 19 of the Code of Federal Regulations (19 C.F.R. § 102.21), implements the URAA. Thus,
the country of origin of a textile or apparel product will be determined by the sequential application of the
general rules set forth in paragraphs (c)(1) through (5) of section 102.21 and, where appropriate to the
specific context, by application of the additional requirements or conditions of section 102.12 through 102.19
of this part. Section 102.15(a)(1) instructs Customs to disregard packaging materials and containers in which
a good is packaged for retail sale that are classified with the good when determining whether the good
undergoes the applicable change in tariff classification set out in Section 102.21. Since the backpack and
stuff sack have been determined to be a container in which the tent or mesh insert is packaged for retail sale
and classified with the tent or mesh insert, the backpack and the stuffed sack fabrics are not considered when
determining the origin of the tent.
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 Big House 4, Big House 6, Bunk House 4, and Bunk House 6 tents are classified under subheading
6306.22, HTSUS. The Sage Canyon Mesh Insert is classified under subheading, 6307.90.9891, 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 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.
6307.90 The country of origin of a good classifiable under 6307.90 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 fabrics for the “Big House 4,” “Big House 6,” “Bunk House 4,” “Bunk House 6,” and the “Sage Canyon
Mesh Insert,” are manufactured in China and Korea.
General Rule (c) of Part 102.21 states that “Subject to paragraph (d) of this section, the country of origin of a
textile or apparel product shall be determined by sequential application of paragraphs (c)(1) through (5) of
this section and, in each case where appropriate to the specific context, by application of the additional
requirements or conditions of 102.12 through 102.19 of this part.” Section 102.13, which sets out the De
Minimis rule states, in relevant part:
(c) Foreign components or materials that do not undergo the applicable change in tariff classification
set out in Section 102.21 or satisfy the other applicable requirements of that section when
incorporated into a textile or apparel product covered by that section shall be disregarded in
determining the country of origin of the good if the total weight of those components or materials is
not more than 7 percent of the total weight of the good.
As you have stated, the weight of the mesh fabric from Korea is not more than 7 percent of the total weight
of each of the finished tents, the mesh fabric is disregarded when determining the country of origin.
Accordingly, the “Big House 4,” “Big House 6,” “Bunk House 4,” and “Bunk House 6,” style tents comply
with the terms of the tariff shift rule for heading 6306, HTSUS; the country of origin is conferred by the
single country in which the woven fabric comprising the tent was formed by the fabric-making process.
Hence, the country of origin of the “Big House 4,” “Big House 6,” “Bunk House 4,” and “Bunk House 6,”
style tents is China.
With respect to the “Sage Canyon Mesh Insert,” the fabrics are manufactured in China and South Korea. The
fabric for the insert body is woven in China. The mesh is knitted in South Korea. As the fabrics comprising
the “Sage Canyon Mesh Insert” are not formed in a single country and the mesh fabric is more than 7
percent of the total weight of the finished mesh insert, the tariff shift rule under Section 12.21(c)(2) is not
applicable.
Section 102.21(c)(3) states that, "Where the country of origin of a textile or apparel product cannot be
determined under paragraph (c)(1) or (2) of this section":
(i) 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
(ii) Except for goods of heading 5609, 5807, 5811, 6213, 6214, 6301 through 6306, and 6308, and
subheadings 6209.20.5040, 6307.10, 6307.90, and 9404.90, 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.
With respect to the “Sage Canyon Mesh Insert”, as the insert is not knit to shape and heading 6307.90 is
excepted from paragraph (ii), Section 102.21 (c)(3) is inapplicable.
Section 102.21 (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." It is the belief of this office that in the case of the “Sage Canyon Mesh Insert,” the most important
manufacturing process occurs at the time of the fabric making. As the fabric for the insert is formed in more
than one country, and no one fabric is more important than the other, country of origin cannot be readily
determined based on the fabric making process. As such, paragraph (c)(4) is not applicable.
Paragraph (c)(5) states that "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, with respect to the “Sage Canyon Mesh Insert,” country of origin is conferred by the last
country in which an important assembly occurred, that is, Vietnam, where the components were cut, sewn,
and packed.
HOLDING:
The applicable subheading for the “Big House 4,” “Big House 6,” “Bunk House 4,” and “Bunk House 6,”
style tents will be 6306.22, HTSUS, and the country of origin is China, including for purposes of determining
the applicable section 301 duties.
The applicable subheading for the “Sage Canyon Mesh Insert,” will be 6307.90.9891, HTSUS, and the
country of origin is Vietnam.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 6306.22, HTSUS, listed above.
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 of China, Hong
Kong, and Macau 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, i.e., 9903.01.25, in addition
to subheading 6306.22, HTSUS, listed above.
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 of Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading
6307.90.9891, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6306.22, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e.,
9903.88.15, in addition to subheading 6306.22, 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 identified in the
ruling request. This position is clearly set forth in section 19 CFR 177.9(b)(1). This section states that a
ruling letter, either directly, by reference, or by implication, is accurate and complete in every material
respect.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
Should it be subsequently determined that the information furnished is not complete and does not comply
with 19 CFR 177.9(b)(1), the ruling will be subject to modification or revocation. In the event there is a
change in the facts previously furnished, this may affect the determination of country of origin. Accordingly,
if there is any change in the facts submitted to Customs, it is recommended that a new ruling request be
submitted in accordance with 19 CFR 177.2.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact
National Import Specialist Kristine Dodge at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division