OT:RR:NC:N1:358
Jo-Anne Daniels
Jo-Anne Daniels DBA Trade Resources & Associates
230-B Tyson Avenue
Paris, TN 38242
RE: The country of origin determination for a bib set; 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., on five items. This letter will address the bib set. The other products will be
addressed in a separate ruling letter. In lieu of samples, images of the items were provided with your request.
Item # BC-XXBS-1X, described as a “Crane Baby Coastal Bandana Bibs,” is a collection of three bibs
constructed of two layers of a 100 percent cotton woven muslin printed fabric. The bibs feature a rounded
body panel with a neck opening, a button snap-closure positioned at the upper portion of the bib and printed
decorative designs.
You state the manufacturing operations for the bib 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 and sewn into bibs.
Cotton loop tape and labels are produced.
The finished bibs are packaged and exported to the United States.
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withdrawn from warehouse, for consumption on or after July 1, 1996.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 bibs
are classified under subheading 6209.20, Harmonized Tariff Schedule of the United States (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
6209.20.5045 - 1) If the good consists of two or more component parts, a change to an assembled
6209.90.9000 good of subheading 6209.20.5045 through 6209.90.9000 from unassembled
components, provided that the change is the result of the good being wholly
assembled in a single country, territory, or insular possession.
(2) If the good does not consist of two or more component parts, a change to
subheading 6209.20.5045 through 6209.90.9000 from any heading, except from
heading 5007, 5111 through 5113, 5208 through 5212, 5309 through 5311, 5407
through 5408, 5512 through 5516, 5602 through 5603, 5801 through 5806, 5809
through 5811, 5903, 5906 through 5907, 6217, subheading 6307.90, and from
babies' garments and clothing accessories of heading 9619, and provided that the
change is the result of 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.
In this case, the bib consists of two or more component parts, but it is not wholly assembled in one country.
Thus, paragraph (c)(2) is not applicable.
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.” The bib is not knit to
shape and, as stated above, it is not wholly assembled in a single country. Therefore, the country of origin
cannot be determined under paragraph 3(c). 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
this case, the cotton muslin fabric used to produce the bibs, is fully formed, printed, and finished in
Uzbekistan prior to export to India. Accordingly, the fabric-making process in Uzbekistan, constitutes the
most important manufacturing process. Therefore, the country of origin of the subject bibs is Uzbekistan.
HOLDING:
The country of origin of item #BC-XXBS-1X, described as a “Crane Baby Coastal Bandana Bibs” 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 Katherine Souffront at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division