OT:RR:NC:N2:349
Mr. Nhep Bunthanith
Tomkins Chamois (Cambodia) Co., Ltd.
Land No. 560, Oukorki Village, Tang Krouch Commune, Samrong Tong District
Phnom Penh 050111
Cambodia
RE: Country of origin determination for a microfiber cleaning cloth; 19 CFR 102.21(c)(2); tariff shift
Dear Mr. Bunthanith:
This is in reply to your letter dated December 16, 2025, requesting a country of origin determination for a
microfiber cleaning cloth, which will be imported into the United States.
Article #71117/1, described as the NIGRIN™ “Microfiber Cloth,” is an 85 percent polyester and 15 percent
polyamide microfiber knit pile cleaning cloth designed to be used for cleaning the interior surfaces of a
vehicle. The sample is dyed black but the cleaning cloth may be offered in other colors, including white. It
features a shallow triangular shaped self-fabric pocket at one of the corners. The pocket is embroidered with
the word “COCKPIT.” This pocket is designed to accommodate the user’s fingers to provide additional
control when cleaning tight or intricate areas of a vehicle. The cloth measures approximately 15 x 15 inches
and all edges are finished with an overlock stitch. The item is packaged with a header card and imported for
retail sale.
The manufacturing operations for the microfiber cleaning cloth are as follows:
China:
Fabric is knit and, depending on the color, either bleached or dyed.
Knit pile fabric is shipped in rolls to Cambodia.
Cambodia:
Sewing thread, embroidery thread, label, header card and packing is manufactured.
Knit pile fabric is cut to shape and size, pocket is formed and sewn to one corner, and all edges are
sewn with an overlock stitch.
The pocket is embroidered with word “Cockpit.”
The finished microfiber cleaning cloth 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withdrawn from warehouse, for consumption on or after July 1, 1996.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) 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
6307.10 The country of origin of a good classifiable under subheading 6307.10 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.
The cleaning cloth is classified under subheading 6307.10, Harmonized Tariff Schedule of the United States
(HTSUS). As the fabric forming the microfiber cleaning cloth is formed by the fabric-making process in a
single country, that is, China, as per the terms of the tariff shift requirement, country of origin is conferred in
China.
MARKING:
The marking statute, Section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless
excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a
conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will
permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country
of origin of the article.
As provided in Section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is
considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it
without strain.
With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 CFR 134.41(a)),
provides that as a general rule marking requirements are best met by marking worked into the article at the
time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk,
molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides
that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate
purchaser unless deliberately removed is acceptable.
Section 134.24(d)(2), Customs Regulations 19 CFR 134.24(d)(2), requires disposable containers or holders
of imported merchandise, which are sold without normally being opened by the ultimate purchaser to be
marked to indicate the country of origin of their contents.
We note that the retail packaging in which the sample was provided indicates “Made in Cambodia” and that
the sample itself is not marked with the country of origin. As such, given the facts provided in your ruling
request, the NIGRIN™ “Microfiber Cloth” does not satisfy the marking requirements under 19 U.S.C. 1304
and 19 CFR 134. The requirements are not met because the incorrect country of origin is shown on the retail
packaging. The retail packaging must be marked with the country of origin of the cleaning cloth, e.g., “Made
in China,” in place of “Made in Cambodia” in order to satisfy 19 U.S.C. 1304 and 19 CFR 134.
HOLDING:
The country of origin of Article #71117/1, described as the NIGRIN™ “Microfiber Cloth,” is China pursuant
19 CFR 102.21(c)(2). The sample provided is not properly marked and does not satisfy the requirements of
19 U.S.C. 1304 and 19 CFR 134.
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