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 wool duvet insert; 19 CFR 102.21(c)(4); most important assembly
or manufacturing process
Dear Ms. Shan:
This is in reply to your letter dated September 4, 2025, requesting a country of origin determination for a
wool duvet insert which will be imported into the United States. Photographs of the item were submitted in
lieu of a sample.
FACTS:
SKU #11194, described as an “All Season Wool Comforter (CMF),” is a quilted duvet insert intended to be
inserted into a separately imported duvet cover. The outer shell of the duvet is composed of 100 percent
cotton woven fabric. The fabric is desized, shrunk and dyed white; it is not printed. The duvet is stuffed
with 100 percent wool nonwoven batting. The three layers are quilted together in a box grid pattern. The
edges of the duvet are finished with self-fabric piping not exceeding 6.35 mm wide sewn between the front
and back panels with a double straight stitch. The duvet insert features a self-fabric loop at each corner. The
loops are used to secure the duvet insert inside a duvet cover to prevent the duvet from bunching up or
shifting. The duvet insert does not contain any embroidery, lace, braid, edging, trimming, and applique
work. The duvet insert is packaged at retail in polyethylene (PE) bag and available in the following product
number and sizes:
Name Product number Dimensions
All Season Wool Comforter (CMF) Twin Natural 25WDT01 70 x 90 inches
All Season Wool Comforter (CMF) Twin XL Natural 25WDT02 70 x 96 inches
All Season Wool Comforter (CMF) Full Natural 25WDT03 84 x 90 inches
All Season Wool Comforter (CMF) Queen Natural 25WDT04 90 x 96 inches
All Season Wool Comforter (CMF) King Natural 25WDT05 108 x 96 inches
The manufacturing operations for the wool duvet insert are as follows:
Pakistan
Cotton fabric is woven.
Cotton fabric is shipped in rolls to China.
New Zealand
Wool fiber is sourced.
Wool fiber is shipped to China.
China
Nonwoven wool batting is produced.
Thread, cotton piping cord, self-fabric piping, polyethylene (PE) bag and labels are produced.
Fabrics are cut, assembled and quilted.
Labels, self-fabric corner loops and self-fabric piping are sewn to finish the duvet insert.
The finished duvet insert is packaged and shipped to 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 USC § 3592), enacted on
December 8, 1994, provides the rules of origin for textiles and apparel products entered, or withdrawn from
warehouse for consumption, on and after July 1, 1996. 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 duvet insert is classified under subheading 9404.40.10, Harmonized Tariff Schedule of the United States
(HTSUS). Prior to 2022, the corresponding HTSUS to subheading 9404.40.10 was subheading 9404.90.80.
Section 102.21 has not been updated with the current tariff subheadings. Therefore, we follow the rule
corresponding to the prior classification, below. See New York Ruling Letter (“NY”) N338830.
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
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; or
Subheading 9404.90.80, HTSUS, is not provided for under paragraph (e)(2), therefore, paragraph (e)(2) is not
applicable. As the duvet insert is comprised of fabric sourced from more than one country, i.e., the outer
shell is formed in Pakistan and the nonwoven batting is formed in China, there is no single country in which
the fabric was formed; therefore, the tariff shift under paragraph (e)(1) is not applicable. Accordingly,
Section 102.21(c)(2) is not applicable to this merchandise.
Paragraph (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.
As this merchandise is not knit to shape and subheading 9404.90, HTSUS, is excepted from provision (ii),
paragraph (c)(3) is inapplicable.
Paragraph (c)(4) states that, "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 duvet insert, the fabric making process of the duvet’s outer shell constitutes the most
important manufacturing process. See HQ 959813. It is the outer shell which actually forms the
merchandise. Therefore, the country of origin of the subject duvet insert is where the fabric forming the
outer shell was formed, that is, Pakistan.
HOLDING:
The country of origin of the duvet insert, SKU #11194, described as a “All Season Wool Comforter (CMF),”
is Pakistan pursuant to 19 CFR 102.21(c)(4).
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 Kim Wachtel at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division