OT:RR:NC:N2:349
Ms. Jo-Anne Daniels
Jo-Anne Daniels DBA Trade Resources & Associates
230-B Tyson Avenue
Paris, TN 38242
RE: Country of origin determination for a washcloth set, burp cloth set, hooded towel, and blanket; 19 CFR
102.21(c)(2); tariff shift; 19 CFR 102.21(c)(4); most important assembly or manufacturing process
Dear Ms. Daniels:
In your letter, dated November 24, 2025, you requested a country of origin determination on behalf of your
client, Crane USA, Inc., for five items. This letter will address the washcloth set, burp cloth set, hooded
towel, and muslin blanket. The bib set will be addressed under NY Ruling N356766. In lieu of samples,
photographs of the items were provided with your request.
Item #BC-160WC-1, described as a “Cove 5 pc Cotton Baby Washcloth Set (Sea Life),” is a set of five
washcloths constructed of two layers of 100 percent cotton muslin printed fabric. The washcloths feature
rounded corners and a hanging loop composed of 100 percent cotton woven fabric attached to one corner.
Each washcloth is 12 inches square and has a knife edge. Each washcloth is washable and reusable. You
state that these washcloths are sold at retail in various designs in set quantities of 3, 4, and 5 on the Crane
website and other online retailers and at baby boutiques.
Item #BC-100BCS-2, described as a “Parker 3-pc Newborn Burp Cloth Set (Rainbow/Butterfly),” is a set of
three burping cloths designed for use over the shoulder to protect an adult’s clothing from spit-up and stains
while holding and burping an infant. Each of the burping cloths is composed of two layers of textile fabrics:
a 100 percent cotton woven muslin printed or dyed solid face fabric and a 100 percent cotton woven jersey
backing. Each 7 x 20 inch, rectangular-shaped, burping cloth features rounded corners and is finished with a
½-inch-wide 100 percent cotton woven sateen binding. Each burping cloth is washable and reusable. Each
burping cloth in the three-piece set features a different face fabric design. You state the burping cloths will
always be sold as a three-piece set and available in different face fabric designs.
Item# BC-160HT-1, described as a “Cove Baby Hooded Towel (Dot),” is an infant’s hooded bath towel that
measures approximately 30 x 30 inches. The body of the towel is made of two layers: a face layer of 100
percent cotton sateen, printed fabric and a backing of 100 percent cotton terry toweling. One corner of the
towel has two layered triangular pieces that form a pocket. The top triangular piece is composed of 100
percent cotton sateen fabric and the bottom layer is 100 percent cotton terry toweling. This pocket is used as
a hood to cover an infant's head after a bath, while the rest of the towel is used to dry off or to cover the
infant. The hood features a pompon and self-fabric sateen hanging loop on the top center of the hood. The
towel is finished with 100 percent cotton sateen binding along its edges. The infant’s hooded bath towel will
be sold, individually, at retail on the Crane website and other online retailers and at baby boutiques.
Item #BC-140BL-1, described as a “6-Layer Muslin Cotton Baby Blanket (Rose Pink),” is a blanket
constructed of six layers of 100 percent cotton, dyed, double gauze woven fabric. The blanket is finished
with tassel lace around the edges. The blanket measures 30 × 40 inches and is machine washable. The
blanket is sold, individually, at retail on the Crane website and other online retailers and at baby boutiques.
You state the manufacturing operations for the washcloth set are as follows:
UZBEKISTAN:
100 percent cotton muslin fabric is woven, dyed or printed and exported in rolls to India.
100 percent cotton thread is formed and exported to India.
INDIA:
Fabric is cut, sewn and assembled into washcloths.
Cotton loop tape and labels are produced.
The finished washcloths are packaged and exported to the United States.
You state the manufacturing operations for the burp cloth set are as follows:
UZBEKISTAN:
100 percent cotton muslin fabric is woven, printed, and exported in rolls to India.
100 percent cotton jersey fabric is woven and exported in rolls to India.
100 percent cotton sateen binding is woven and exported in rolls to India.
100 percent cotton thread is produced and exported to India.
INDIA:
Fabric is cut to shape and size.
Fabric is sewn to create a burping cloth.
The burping cloths are packaged and exported to the United States.
You state the manufacturing operations for the hooded towel are as follows:
UZBEKISTAN:
100 percent cotton terry toweling is woven, washed and exported in rolls to India.
100 percent cotton sateen fabric is woven, printed and exported in rolls to India.
100 percent cotton thread is formed and exported to India.
INDIA:
Tassel/pompon and labels are produced.
Fabric is cut, sewn and assembled into a hooded towel.
The finished hooded blanket is packaged and exported to the United States.
You state the manufacturing operations for the muslin blanket are as follows:
UZBEKISTAN:
100 percent cotton double gauze fabric is woven, dyed, and exported in rolls to India.
100 percent cotton thread is formed and exported to India.
INDIA:
Fabric is cut, sewn and assembled into blanket.
Tassel lace and labels are produced.
The finished blanket is packaged and exported to the 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 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
washcloth is classified under subheading 6302.91, Harmonized Tariff Schedule of the United States
(HTSUS). The burp cloth set is classified under subheading 6307.90, HTSUS. The hooded towel is
classified under subheading 6302.60, HTSUS, and the blanket is classified under heading 6301, 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
6301 - 6306 Except for goods of heading 6302 through 6304 provided for in paragraph
(e)(2) of this section, the country of origin of a good classifiable under
heading 6301 through 6306 is the country, territory, or insular possession in
which the fabric comprising the good was formed by a fabric-making
process.
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.
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;
As paragraph (e)(2) does not apply to the tariff shift rules for headings 6301, HTSUS, and 6307, HTSUS, and
neither subheading 6302.60, HTSUS, nor subheading 6302.91, HTSUS, are listed in paragraph (e)(2),
paragraph (e)(2) does not apply to any of the items under consideration. Based on the information provided
in your letter, the burp cloths and hooded towels consist of fabric formed by the fabric-making process in a
single country. Therefore, in accordance with paragraph (e)(1), as the fabric for the burp cloths and hooded
towels are formed by the fabric-making process in a single country, that is, Uzbekistan, as per the terms of
the tariff shift requirement, country of origin is conferred in Uzbekistan.
The fabric-making process for the washcloths and blanket does not occur in a single country. The washcloths
are comprised of muslin fabric woven in Uzbekistan and cotton loop tape woven in India. The blanket is
comprised of double gauze fabric woven in Uzbekistan and tassel lace formed in India. Therefore, Section
102.21(c)(2) is inapplicable and we proceed to paragraph (c)(3).
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 subject
merchandise is not comprised of fabrics that are knit to shape, and headings 6301 and 6302, and subheading
6307.90, HTSUS, are excepted under provision (ii), Section 102.21 (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 washcloths and blankets, the fabric-making process of the double gauze muslin
comprising the main body of the blanket and the muslin fabric forming the main body of the washcloths
constitutes the most important manufacturing processes. It is the six layers of double gauze muslin
comprising the blanket and two layers of muslin fabric comprising the washcloth which actually form the
merchandise. Accordingly, the fabric-making process in Uzbekistan, where the muslin fabrics for the blanket
and washcloth are formed constitutes the most important manufacturing process. Therefore, the country of
origin of the subject washcloths and blankets is Uzbekistan.
HOLDING:
The country of origin of item #BC-100BCS-2, described as a “Parker 3-pc Newborn Burp Cloth Set
(Rainbow/Butterfly)” and item# BC-160HT-1, described as a “Cove Baby Hooded Towel (Dot)” is
Uzbekistan pursuant to 19 CFR 102.21(c)(2). The country of origin of item #BC160WC-1, described as
“Cove 5 pc Cotton Baby Washcloth Set (Sea Life)” and item #BC-140BL-1, described as a “6-Layer Muslin
Cotton Baby Blanket (Rose Pink),” is Uzbekistan pursuant to 19 CFR 102.21(c)(4).
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division