OT:RR:NC:N4:441
Chris Tovar
CST Inc.
500 Westpark Drive, Suite 230
Peachtree City, GA 30269
RE: The tariff classification and country of origin for backpacks from Cambodia; 19 CFR 102.21 (c)(2); tariff
shift
Dear Mr. Tovar:
In your letter dated October 29, 2025, you requested a country of origin ruling on two backpacks on behalf of
your client, Cliff Keen Athletic. You have submitted photographs and descriptive literature for our review.
Styles ABP18 and ABPI3JR are backpacks constructed with an outer surface of man-made textile material.
They are designed and sized to provide storage, protection, portability, and organization to personal effects
during travel.
You have indicated that the locations of the manufacturing operations are as follows:
China:
The fabric and all materials are sourced and produced.
Bolts of fabric are shipped to Cambodia.
Cambodia:
All cutting, sewing, and assembly steps are performed.
CLASSIFICATION
The applicable subheading for the backpacks will be 4202.92.3120, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for travel, sports, and similar bags, with outer surface of textile
materials, of man-made fibers, backpacks. The general rate of duty will be 17.6 percent ad valorem.
COUNTRY OF ORIGIN
Section 334 of the Uruguay Round Agreements Act (codified at 19 U.S.C. 3592), enacted on December 8,
1994, provided rules of origin for textiles and apparel entered, or withdrawn from warehouse for
consumption, on and after July 1, 1996. Section 102.21, Customs Regulations (19 C.F.R. 102.21), published
September 5, 1995 in the Federal Register, implements Section 334 (60 FR 46188). Section 334 of the
URAA was amended by section 405 of the Trade and Development Act of 2000, enacted on May 18, 2000,
and accordingly, section 102.21 was amended (68 Fed. Reg. 8711). Thus, 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.
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.” Since 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
4202.92.15-4202.92.33 A change to subheading 4202.92.15 through 4202.92.33 from any other
heading, provided that the change is the result of the good being wholly
assembled in a single country, territory, or insular possession.
The backpacks are fully assembled in Cambodia from fabric and other materials all of which are provided for
outside of Heading 4202. As such, they meet the terms of the tariff shift requirement for subheading
4202.92.31 in Section 102.21(c)(2). Accordingly, the country of origin of the subject items 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 of Cambodia will
be subject to an additional ad valorem rate of duty of 19 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.11 in addition to subheading
4202.92.3120, HTSUS, listed above.
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 Vikki Lazaro at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division