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 fitted sheet, flat sheet, pillowcase set, and duvet cover; 19 CFR
102.21(c)(2); tariff shift
Dear Ms. Daniels:
This is in reply to your letter dated December 13, 2025, requesting a country of origin determination on
behalf of your client, Crane USA Inc., for a fitted sheet, flat sheet, pillowcase set, and duvet cover, which
will be imported into the United States. Photographs and specifications of each item were submitted in lieu
of the samples.
Item #CH-200FS, described as “Calm Crinkled Comfort Fitted Sheet (Morning Fog),” consists of a fitted
sheet constructed of 100 percent cotton gauze fabric that is yarn dyed. The fabric may be napped and/or
printed. The fitted sheet is finished with a tunneled, elasticized edge and does not contain any embroidery,
lace, braid, edging, trimming, piping or applique work. The fitted sheet is available in three sizes: Full
(CH-200FS-FL), Queen (CH-200FS-QN) and a King (CH-200FS-KG). The fitted sheet is packaged and
imported inside a fabric drawstring bag.
Item #CH-200TS, described as “Calm Crinkled Comfort Flat Sheet (Morning Fog),” consists of a flat sheet
constructed of 100 percent cotton gauze fabric that is yarn dyed. The fabric may be napped and/or printed.
The flat sheet is finished with a ½ inch wide hem along all four sides and does not contain any embroidery,
lace, braid, edging, trimming, piping or applique work. The flat sheet is available in three sizes: Full
(CH-200TS-FL), Queen (CH-200TS-QN) and a King (CH-200TS-KG). The flat sheet is packaged and
imported inside a fabric drawstring bag.
Item #CH-200PC, described as “Calm Crinkled Comfort Pillowcase Set – Set of 2 (Morning Fog),” consists
of two pillowcases constructed of 100 percent cotton gauze fabric that is yarn dyed. The fabric may be
napped and/or printed. The pillowcase is constructed from a single piece of fabric, folded and sewn along
two edges, and hemmed at the open edge. It does not contain any embroidery, lace, braid, edging, trimming,
piping or applique work. The pillowcase set is available in two sizes: Standard (CH-200PC-QN), and a King
(CH-200PC-KG). The 2-piece set of pillowcases is packaged and imported inside a fabric drawstring bag.
Item #CH-210DC, described as “Rust Crinkled Linen Duvet Cover,” consists of a duvet cover. The face of
the duvet cover is composed of 87 percent cotton and 13 percent linen gauze fabric that is yarn dyed. The
face fabric may be napped and/or printed. The backing is composed of 87 percent cotton and 13 percent
linen woven fabric that is yarn dyed and is neither printed nor napped. The duvet cover has a knife edge and
an opening at the bottom end with an eight-button closure. It does not contain any embroidery, lace, braid,
edging, trimming, piping or applique work. The duvet cover is available in two sizes: Queen, 92 × 88
inches, (CH210DC-QN) and a King, 92 × 108 inches, (CH210DC-KG).
The manufacturing operations for the fitted sheet are as follows:
UZBEKISTAN:
Cotton is grown and yarn is spun, scoured, bleached, dyed, washed and dried.
Cotton gauze fabric is woven.
Cotton fabric for bag is woven.
Elastic band is woven.
Cotton drawstring used for closure on the fabric bag is produced.
Gauze fabric is singed, washed, dried, printed, heat cured or steamed, stretched, softened and
inspected.
Finished cotton gauze fabric for the fitted sheet, cotton dyed woven fabric for the bag, and the
drawstring are shipped in rolls and spools to India.
INDIA:
Gauze fabric is cut to size.
Corners are cut and sewn to form fitted shape.
Elastic is sewn in the hem around the edges.
Labels are attached by sewing.
Fabric for drawstring cotton bag is cut and assembled by sewing and drawstring is tunneled through
hem at open end.
Finished fitted sheet is folded and packaged inside cotton drawstring bag.
Retail packaged fitted sheets are packaged in cartons, palletized, labeled and exported to the United
States.
The manufacturing operations for the flat sheet are as follows:
UZBEKISTAN:
Cotton is grown and yarn is spun, scoured, bleached, dyed, washed and dried.
Cotton gauze fabric is woven.
Cotton fabric for bag is woven.
Cotton drawstring used for the closure on the fabric bag is produced.
Gauze fabric is singed, washed, dried, printed, heat cured or steamed, stretched, softened and
inspected.
Finished cotton gauze fabric for the flat sheet, cotton dyed woven fabric for the bag, and the drawstring
are shipped in rolls and spools to India.
INDIA:
Gauze fabric is cut to size and hemmed.
Labels are attached by sewing.
Fabric for drawstring cotton bag is cut and assembled by sewing and drawstring is tunneled through
hem at open end.
Finished flat sheet is folded and packaged inside cotton drawstring bag.
Retail packaged flat sheets are packaged in cartons, palletized, labeled and exported to the United
States.
The manufacturing operations for the pillowcase set are as follows:
UZBEKISTAN:
Cotton is grown and yarn is spun, scoured, bleached, dyed, washed and dried.
Cotton gauze fabric is woven.
Cotton fabric for bag is woven.
Cotton drawstring used for the closure on the fabric bag is produced.
Gauze fabric is singed, washed, dried, printed, heat cured or steamed, stretched, softened and
inspected.
Finished cotton gauze fabric for pillowcase, cotton dyed woven fabric for the bag, and the drawstring
are shipped in rolls and spools to India.
INDIA:
Gauze fabric is cut to size and assembled by sewing.
Labels are attached by sewing.
Fabric for drawstring cotton bag is cut and assembled by sewing and drawstring is tunneled through
hem at open end.
2-piece pillowcase set is folded and packaged inside cotton drawstring bag.
Retail packaged pillowcases are packaged in cartons, palletized, labeled and exported to the United
States.
The manufacturing operations for the duvet cover are as follows:
UZBEKISTAN:
Cotton is grown and yarn is spun, scoured, bleached, dyed, washed and dried.
Cotton greige gauze face fabric and cotton back fabric are woven.
Greige fabric is singed, washed, dried, printed, heat cured or steamed, stretched, softened and
inspected.
Finished woven fabrics for duvet cover are shipped in rolls to India.
INDIA:
Buttons are produced.
Cotton fabrics are cut to size and assembled by sewing.
Buttons and labels are attached by sewing.
Finished duvet cover is folded and wrapped with a ribbon label card packaged inside a polybag.
Retail packaged duvet covers are packaged in cartons, palletized, labeled 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. The fitted sheet, top (flat) sheet, pillowcase, and duvet cover are
classified under subheading 6302.21, Harmonized Tariff Schedule of the United States (HTSUS), if printed,
and under subheading 6302.31, HTSUS, if not printed.
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.
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;
***
The sheets, pillowcases and duvet covers are classified under subheadings 6302.21 and 6302.31, Harmonized
Tariff Schedule of the United States (HTSUS), which are not included in the paragraph (e)(2) exception to
the above tariff shift rule. Therefore, as the fitted sheet, flat sheet, pillowcases and duvet cover are made
from fabric that is formed by the fabric-making process in a single country, that is, Uzbekistan, the country of
origin is conferred in Uzbekistan.
HOLDING:
The country of origin of the fitted sheet, top (flat) sheet, pillowcase, and duvet cover is Uzbekistan pursuant
19 CFR 102.21(c)(2).
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