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 pad; 19 CFR 102.21(c)(5); last country in which an
important assembly or manufacturing process occurred
Dear Ms. Shan:
This is in reply to your letter dated September 3, 2025, requesting a country of origin determination for a
mattress pad which will be imported into the United States. Photographs and a technical diagram of the item
were submitted in lieu of a sample.
FACTS:
The item, identified as a “LH Loftaire Ultra Mattress Pad,” is a quilted mattress pad comprised of an outer
shell of 100 percent cotton sateen fabric that is filled with 100 percent polyester fiberfill. The shell fabric is
both bleached and dyed white. The top and bottom panels that make up the shell and the polyester fiberfill
are quilted together. The quilted pad is designed to cover the entire top of a mattress and is held in place by a
fully elasticized skirt made of 100 percent cotton jersey knit fabric with a depth of 18 inches. The mattress
pad is packaged in a polyethylene (PE) bag and sold at retail. The mattress pad is available in the following
SKU #s, Product #s and sizes:
Name SKU # Product # Sizes
LH LOFTAIRE ULTRA MATTRESS PAD TWIN WHITE 11222-T-White 25LUMP01 39 x 75 x 18 inches
LH LOFTAIRE ULTRA MATTRESS PAD TWIN XL WHITE 11222-TXL-White 25LUMP02 39 x 80 x 18 inches
LH LOFTAIRE ULTRA MATTRESS PAD FULL WHITE 11222-F-White 25LUMP03 54 x 75 x 18 inches
LH LOFTAIRE ULTRA MATTRESS PAD QUEEN WHITE 11222-Q-White 25LUMP04 60 x 80 x 18 inches
LH LOFTAIRE ULTRA MATTRESS PAD KING WHITE 11222-K-White 25LUMP05 78 x 80 x 18 inches
LH LOFTAIRE ULTRA MATTRESS PAD CAL KING WHITE 11222-CK-White 25LUMP06 72 × 84 x 18 inches
The manufacturing operations for the mattress pad are as follows:
PAKISTAN
Cotton sateen fabric is woven.
Cotton sateen fabric is exported to China.
CHINA
Cotton sateen fabric is bleached and dyed white.
Cotton jersey fabric is knit and bleached.
Polyester fiberfill and elastic are formed.
Sewing thread, labels, PE bag, and packing cartons are produced.
Sateen fabric is cut and assembled by sewing into a mattress pad shell.
The mattress pad is filled with polyester fiberfill and sewn closed with labels.
Cotton jersey knit skirting fabric and elastic are cut, sewn and assembled to the mattress pad.
The completed mattress pad is packaged and exported to the United States.
ISSUE:
What is 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)(1) provides the rules used to determine the country of origin of a textile or apparel product
under paragraph (c)(2) of this section. These rules are dependent on the classification of the good. The
mattress pad is 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 “fabric-making process” is defined in section 102.21(b)(2) as follows:
A “fabric-making process” is any manufacturing operation that begins with polymers, fibers,
filaments (including strips), yarns, twine, cordage, rope, or fabric strips and results in a textile fabric.
Paragraph (e)(2), in pertinent part, states,
For goods of HTSUS headings 6213 and 6214 and HTSUS subheadings 6117.10, 6302.22, 6302.29,
6302.52, 6302.53, 6302.59, 6302.92, 6302.93, 6302.99, 6303.92, 6303.99, 6304.19, 6304.93,
6304.99, 9404.90.85 and 9404.90.95, except for goods classified under those headings or subheadings
as of cotton or of wool or consisting of fiber blends containing 16 percent or more by weight of
cotton:
(i) The country of origin of the good is the country, territory, or insular possession in which the fabric
comprising the good was both dyed and printed when accompanied by two or more of the following
finishing operations: bleaching, shrinking, fulling, napping, decating, permanent stiffening,
weighting, permanent embossing, or moireing;
(ii) If the country of origin cannot be determined under paragraph (e)(2)(i) of this section...the country
of origin is the country, territory, or insular possession in which the fabric comprising the good was
formed by a fabric-making process;
Prior to 2022, the corresponding HTSUS to subheading 9404.90.81 was 9404.90.80. Paragraph (e)(2) has not
been updated with the current tariff subheadings. Therefore, we follow the rule corresponding to the prior
classification. Subheading 9404.90.80 is not included among the paragraph (e)(2) exceptions to the above
tariff shift rule; however, as the fabric forming the mattress pad is not formed 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:
(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 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 mattress pad is not knit to shape and subheading 9404.90, HTSUS, is excepted from provision (ii),
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 mattress pad, the fabric making process constitutes the most important manufacturing process.
See NY E80405 (May 14, 1999), NY H85550 (Sept. 4, 2001) and Headquarters Ruling Letter (“HQ”)
959256 (June 20, 1996). Since the fabric for the mattress pad is formed in two countries, a single country of
origin determination cannot be made based on Section 102.21(c)(4).
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 mattress pad, country of origin is conferred by the last country in
which an important assembly or manufacturing process occurred, that is, China.
HOLDING:
The country of origin of the subject mattress pad is China pursuant to 19 CFR 102.21(c)(5).
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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division