OT:RR:NC:N3:351
Mr. Barry Hackett
GHF Greendale Home Fashions, LLC
5500 Muddy Creek Road
Cincinnati, OH 45238
RE: Classification and country of origin determination for a pillow shell and pillow; 19 CFR 102.21(c)(2);
tariff shift
Dear Mr. Hackett:
This is in reply to your letter dated November 18, 2025, requesting a classification and country of origin
determination for a pillow shell and pillow which will be imported into the United States. Samples were
provided to this office and will be retained for training purposes.
The sample, item #5811-YELLOW-COVER, is a pillow shell formed from 100 percent polyester woven
fabric dyed yellow. The rectangular shaped pillow shell, measuring 6 x 12 x .35 inches, is sewn with a knife
edge and left unfinished with a 6-inch opening. After importation into the United States, the pillow shell will
be filled with polyester staple fiber and sewn closed.
The sample, item #5811-YELLOW-COMPLETED is a pillow formed from 100 percent polyester woven
fabric dyed yellow. The rectangular shaped pillow, measuring 6 x 12 x 4 inches, is stuffed with polyester
staple fiber and sewn closed.
The manufacturing operations for the pillow shell and pillow are as follows:
United States:
• 100 polyester fabric is woven, dyed, and shipped in rolls to China.
China:
• Polyester fiberfill and polyester thread is formed.
• Polyester fabric is cut and assembled into a pillow shell (#5811-YELLOW-COVER and
#5811-YELLOW-COMPLETED).
• Pillow shell is filled with polyester fiberfill and sewn closed to create a completed pillow
(#5811-YELLOW-COMPLETED).
• Pillow shells and completed pillows are packed and exported to the United States.
United States (After importation):
• Pillow shell (#5811-YELLOW-COVER) is filled with polyester staple fiber and sewn closed.
ISSUE:
What are the classification and country of origin of the subject merchandise?
CLASSIFICATION:
The applicable subheading for the pillow shell will be 6307.90.9891, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Other made up articles, including dress patterns: Other: Other:
Other: Other: Other.” The general rate of duty will be 7 percent ad valorem.
The applicable subheading for the completed pillow will be 9404.90.2090, HTSUS, which provides for
“Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns,
cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of
cellular rubber or plastics, whether or not covered: Other: Pillows, cushions and similar furnishings: Other:
Other.” The general rate of duty will be 6 percent ad valorem.
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) 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
6307.90 The country of origin of a good classifiable under subheading
6307.90 is the country, territory, or insular possession in which
the fabric comprising the good was formed by a fabric-making
process.
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 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,
(2) For goods of HTSUS headings 6213 and 6214 and HTSUS subheadings 6117.10, 6302.22,
6302.29, 6302.53, 6302.59, 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, except for
goods of HTSUS subheading 6117.10 that are knit to shape or consist of two or more component
parts, 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;
As the fabric for the pillow shell is formed by the fabric-making process in a single country, that is, the
United States, as per the terms of the tariff shift requirement, the country of origin for the pillow shell is
conferred in the United States.
The completed pillow is classified under subheading 9404.90.2090, HTSUS. Subheading 9404.90.20,
HTSUS, is not listed as a paragraph (e)(2) exception; therefore, as the only fabric incorporated in the
completed pillow is formed by a fabric-making process in a single country, that is, the United States, as per
the terms of the tariff shift requirement, country of origin for the completed pillow is conferred in the United
States.
Inasmuch as the marking requirements of 19 U.S.C. 1304 are applicable only to articles of “foreign origin,”
the subject outdoor pillows are not required to be marked upon importation into the United States. Whether
an article may be marked with the phrase “Made in the USA” or similar words denoting U.S. origin, is an
issue under the authority of the Federal Trade Commission (FTC). We suggest that you contact the FTC
Division of Enforcement, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580 on the propriety of
proposed markings indicating that an article is made in the U.S.
HOLDING:
The pillow shell is classified under 6307.90.9891, HTSUS, and the country of origin is the United States.
The completed pillow is classified under 9404.90.2090, HTSUS, and the country of origin is the United
States.
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 Kristine Dodge at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division