OT:RR:NC:N2:350
Malanie Jimenez
Hadasa Dance Shop
2502 N 32nd Street B36
Phoenix, AZ 85008
RE: The tariff classification and country of origin of a ribbon with woven selvedges; 19 CFR 102.21 (c)(2)
Dear Ms. Jimenez:
In your letter dated November 13, 2025, you requested a tariff classification and country of origin ruling.
FACTS:
Our office is in receipt of your sample, “WHTRBN-WE001,” which is a 2.2 cm wide woven ribbon which
contains woven selvedges. The ribbon is said to be composed of 100 percent acetate, satin woven
construction, dyed to an off-white color and will be imported on 100 yard rolls.
You indicate that the yarn is produced in the United States. The yarn is then shipped to China where the
ribbon is woven. The undyed ribbon is then exported to the United Kingdom where it is dyed and finished
before being inspected and packed for exportation to the United States.
CLASSIFICATION:
In your submission you suggested classification under subheading 5806.32.1040, Harmonized Tariff
Schedule of the United States (“HTSUS”), which provides for other ribbons of polyester; however, your
ribbon is said to be composed of acetate. Subheading 5806.32.1040 is not applicable.
The applicable subheading for the woven ribbon, “WHTRBN-WE001,” will be 5806.32.1080, HTSUS,
which provides for “Narrow woven fabrics, other than goods of heading 5807; narrow fabrics consisting of
warp without weft assembled by means of an adhesive (bolducs): Other woven fabrics: Of man-made fibers:
Ribbons… Other: Of a width not exceeding 12 cm: Other.” The general rate of duty will be 6 percent ad
valorem.
COUNTRY OF ORIGIN:
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 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withdrawn from warehouse, for consumption on or after July 1, 1996.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.
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 ribbon was not wholly obtained nor produced in a single country, paragraph (c)(1) is not applicable.
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) 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 5806
(1) Except for fabric of wool or of fine animal hair, a change from greige fabric of heading 5806 to
finished fabric of heading 5806 by both dyeing and printing when accompanied by two or more of the
following finishing operations: bleaching, shrinking, fulling, napping, decating, permanent stiffening,
weighting, permanent embossing, or moireing; or
(2) If the country of origin cannot be determined under (1) above, a change to heading 5806 from any
other heading, except from heading 5007, 5111 through 5113, 5208 through 5212, 5309 through
5311, 5407 through 5408, 5512 through 5516, and 5801 through 5803, and provided that the change
is the result of a fabric-making process.
In this case, (1) above is inapplicable to the ribbon as it does not go through a process of both dyeing and
printing while being accompanied by two or more of the other required finishing operations.
In (2) above, the required tariff shifts take place. An acetate yarn, whether of filament fibers or staple fibers,
would be classifiable in heading 5403, or headings 5510 through 5511. The scope of those headings is
outside of the excepted scope of the headings provided for in (2) above. Therefore, with a change of yarns of
heading 5403, or 5510 through 5511 into a fabric of heading 5806 in China, the country of origin will be
conferred in China.
HOLDING:
The applicable subheading for the woven ribbon, “WHTRBN-WE001,” will be 5806.32.1080, HTSUS,
and the country of origin is China pursuant to 19 CFR 102.21(c)(2).
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
The merchandise in question may be subject to antidumping duties and countervailing duties (“AD/CVD”).
Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance
office in the International Trade Administration of the Department of Commerce and are separate from tariff
classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at
https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current
AD/CVD cases at the Department of Commerce ITA website at
https://www.trade.gov/data-visualization/adcvd-proceedings, and you can search AD/CVD deposit and
liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
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 Code of Federal Regulations (19 CFR
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 Michael Capanna at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division