OT:RR:NC:N3:348
John Park
WHL Customs Broker Services
1520 W. Artesia Square
Gardena, CA 90248
RE: Classification and country of origin determination for scarf/sarong; 19 CFR 102.21(c)(2); tariff shift
Dear Mr. Park:
This is in reply to your letter dated October 30, 2025, and additional information received on December 8,
2025, on behalf of DZ Trading LTD, requesting a classification and country of origin determination for a
scarf/sarong, which will be imported into the United States.
The subject merchandise consists of a printed scarf/sarong. Style ATS/271 composed of 100% polyester
woven fabric. The item measures 42” in length and 64” in width. It is a multifunctional piece that can be
worn in different ways. The product is used as a sarong and a scarf.
The manufacturing operations for the scarf/sarong re as follows:
.
The raw polyester fabric is manufactured, bleached and shrunk in China.
The rolled polyester fabric is shipped to Cambodia.
In Cambodia, the fabric is printed, cut, sewn and packaged for export.
The finished products will be exported from Cambodia to US directly.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in
accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that classification
shall be according to the terms of the headings and any relative section or chapter notes and, unless otherwise
required according to the remaining GRI’s taken in order. Goods that are, prima facie, classifiable under two
or more headings, are classifiable in accordance with GRI 3. GRI 3(a) states that the heading providing the
most specific description is to be preferred to a heading which provides a more general description. The item
is classifiable under tariff headings 6211 (other garments) and 6214 (shawls and scarves). Since Style
ATS/271 is classifiable under two headings, application of GRI 3(a) must be applied. In this case, heading
6214 provides the most specific description for Style ATS/271.
The applicable subheading for Style ATS/271 will be 6214.40.0000, HTSUS, which provides for “Shawls,
scarves, mufflers, mantillas, veils and the like: Of artificial fibers.” The rate of duty will be 5.3% ad valorem.
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
6213-6214 Except for goods of heading 6213 through 6214 provided for in paragraph (e)(2) of
this section, the country of origin of a good classifiable under heading 6213 through
6214 is the country, territory, or insular possession in which the fabric comprising
the good was formed by a fabric-making process
As the fabric-making process occurred in China, as per the terms of the tariff shift requirement, country of
origin is conferred in China.
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 Rosemarie Hayward at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division