OT:RR:NC:N2:349
Ms. Fay Xu
Evergrace Home Inc.
5 Floor Sun Shine Mansion
2000 Pudong Avenue
Shanghai 2000135
China
RE: Classification and country of origin determination for a tufted chenille bath mat; 19 CFR 102.21(c)(4);
most important assembly or manufacturing process
Dear Ms. Xu:
This is in reply to your letter dated December 2, 2025, requesting a classification and country of origin
determination for a tufted bath mat and a woven bath mat, which will be imported into the United States.
Two samples of the tufted bath mat were provided. We cannot issue a ruling on the woven bath mat without
a sample. Therefore, this ruling will only address the tufted bath mat for which a sample was provided.
FACTS:
The subject merchandise, Item# ABS202408230033, is a chenille bath mat of tufted construction. The pile
surface is made from twisted, uncut loops of polyester chenille yarns that are tufted into a pre-existing base
consisting of a nonwoven layer of polyester and a woven mesh layer of polypropylene. The tufts are made in
two pile heights, approximately 6 and 13 millimeters (mm), to form a design on the surface. The tufted
fabric is laminated to a 15 mm thick layer of polyurethane (PU) foam which is then backed with a
3-dimensional diamond mesh spacer fabric to create a non-skid surface. The edges of the rug are capped
with a narrow strip of knit binding fabric. The finished mat measures 20 × 32 inches.
The manufacturing operations for the bath mat are as follows:
CHINA:
Chenille yarns are machine tufted into two primary backing fabrics, a nonwoven and a mesh fabric.
Diamond mesh spacer fabric is formed.
Knitted binding fabric is formed.
Fabrics are exported to Vietnam.
VIETNAM:
Foam is formed.
Foam and diamond mesh spacer fabric are laminated to the tufted chenille fabric.
Laminated material consisting of chenille tufted fabric, foam and spacer fabric is cut to size.
Knitted binding is sewn around the edges.
Completed bath mat is packaged and exported to the United States.
ISSUE:
What are the classification and country of origin of the subject merchandise?
CLASSIFICATION:
The applicable subheading for the chenille bath mat, Item# ABS202408230033, will be 5703.39.2030,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Carpets and other textile
floor coverings (including turf), tufted, whether or not made up: Of other man-made textile materials: Other:
Other: Measuring not more than 5.25 m2 in area.” 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
5701 - 5705 A change to heading 5701 through 5705 from any other chapter.
In our opinion the tufted fabric has the thickness, stiffness and strength to render it suitable for use as a floor
covering of heading 5703 prior to being laminated to the foam and spacer fabric. Therefore, the foreign
materials do not undergo the applicable tariff change in a single country, territory or insular possession. The
chenille yarn and the nonwoven and woven mesh primary backing fabrics make the tariff shift in China,
while the foam, spacer fabric and binding fabric make the tariff shift in Vietnam. As each foreign material
does not undergo the applicable change in tariff classification in a single country, Section 102.21(c)(2) is
inapplicable.
Section 102.21(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 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.
The term “wholly assembled” is defined under Section 102.21(b)(6) which states,
(6) Wholly assembled. The term “wholly assembled” when used with reference to a good means that
all components, of which there must be at least two, preexisted in essentially the same condition as
found in the finished good and were combined to form the finished good in a single country, territory,
or insular possession. Minor attachments and minor embellishments (for example, appliques, beads,
spangles, embroidery, buttons) not appreciably affecting the identity of the good, and minor
subassemblies (for example, collars, cuffs, plackets, pockets), will not affect the status of a good as
“wholly assembled” in a single country, territory, or insular possession.
As the subject merchandise is neither knit to shape nor wholly assembled in a single country, Section 102.21
(c)(3) is inapplicable.
Section 102.21 (c)(4) states, “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 bath mat, the tufting of the chenille yarn into the primary backing fabrics constitutes
the most important assembly process. Accordingly, the country of origin of the bath mat, Item#
ABS202408230033, is China.
HOLDING:
The chenille bath mat, Item# ABS202408230033, is classified under subheading 5703.39.2030, HTSUS. The
country of origin of the bath mat is China.
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 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