OT:RR:NC:N2:349
Ms. Fay Xu
Evergrace Home Inc.
5 Floor Sun Shine Mansion
Shanghai 200135
China
RE: Classification and country of origin determination for woven chenille bathmats; 19 CFR 102.21(c)(3);
wholly assembled
Dear Ms. Xu:
This is in reply to your letter dated December 19, 2025, requesting a classification and country of origin
determination for woven chenille bathmats, which will be imported into the United States. A sample of each
of the woven bathmats was provided and will be retained by this office.
FACTS:
The subject merchandise, item numbers ABS202512020036 and ABS202512050003, are woven bathmats
with an exposed surface of 100 percent polyester chenille yarns. Item# ABS202512020036 is constructed by
laminating the woven chenille surface fabric to a .6-inch-thick layer of foam which is then laminated to a
three-dimensional (3D) diamond mesh spacer fabric backing to create a non-skid surface. Item#
ABS202512050003 is constructed by backing the woven chenille surface fabric with a layer of thermoplastic
rubber (TPR). The edges of both bathmats are finished with a narrow strip of knit binding fabric. The
finished mats measure 20 × 34 inches.
The manufacturing operations for the bathmats are as follows:
CHINA:
Woven chenille fabric is formed.
3D diamond mesh fabric is formed. (Item# ABS202512020036)
Binding is knit.
Fabrics are exported to Vietnam.
VIETNAM:
Foam is formed. (Item# ABS202512020036)
Foam and 3D diamond mesh fabric are laminated to the top fabric. (Item# ABS202512020036)
TPR is formed and laminated to woven chenille fabric. (Item# ABS202512050003)
Laminated fabrics are cut to size.
All edges are finished with knitted binding.
Finished bathmats are 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 woven chenille bath mats, item numbers ABS202512020036 and
ABS202512050003, will be 5702.42.2080, Harmonized Tariff Schedule of the United States (HTSUS),
which provides for “Carpets and other textile floor coverings, woven, not tufted or flocked, whether or not
made up, including ‘Kelem,’ ‘Schumacks,’ ‘Karmanie’ and similar handwoven rugs: Other of pile
construction, made up: Of man-made textile materials: Other: Other.” The general rate of duty will be
Free.
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 on World Wide Web at https://hts.usitc.gov/current.
COUNTRY OF ORIGIN - LAW AND ANALYSIS:
Section 334 of the Uruguay Round Agreements Act (codified at 19 U.S.C. 3592), enacted on December 8,
1994, provided rules of origin for textiles and apparel entered, or withdrawn from warehouse for
consumption, on and after July 1, 1996. Section 102.21, Customs Regulations (19 C.F.R. 102.21), published
September 5, 1995 in the Federal Register, implements Section 334 (60 FR 46188). Section 334 of the
URAA was amended by section 405 of the Trade and Development Act of 2000, enacted on May 18, 2000,
and accordingly, section 102.21 was amended (68 Fed. Reg. 8711). Thus, 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.
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 woven chenille fabric has the thickness, stiffness and strength to render it suitable for use
as a floor covering of heading 5702 prior to being laminated to either the foam and spacer fabric or the TPR.
Therefore, each foreign material does not undergo the applicable tariff change in a single country, territory or
insular possession. The chenille fabric makes the tariff shift in China, while the foam, spacer fabric, TPR and
binding 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.
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 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 heading 5702 is not excluded under paragraph (c)(3)(ii) and the subject merchandise is wholly assembled
in a single country, that is, Vietnam, country of origin is conferred in Vietnam.
HOLDING:
The chenille woven bathmats, item numbers ABS202512020036 and ABS202512050003, are classified
under subheading 5702.42.2080, HTSUS. The country of origin of the woven chenille bathmats,
ABS202512020036 and ABS202512050003, is Vietnam pursuant to 19 CFR 102.21(c)(3)(ii).
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 Kim Wachtel at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division