OT:RR:NC:N2:349
Ms. Yaping Shan
Hangzhou Joyce Household Textiles Co., Ltd.
No. 2675 Xinluo Road, Xintang Street, Xiaoshan District,
Hangzhou 311201
China
RE: Country of origin determination for pillow inserts; 19 CFR 102.21(c)(2); tariff shift
Dear Ms. Shan:
This is in reply to your letter dated December 27, 2025, requesting a country of origin determination for
pillow inserts which will be imported into the United States. Photographs and a product specification sheet
were provided in lieu of a sample.
FACTS:
The subject merchandise consists of Down Alternative Firm Density pillow inserts. The pillows are
constructed with an outer shell of 100 percent polyester microfiber woven fabric that is bleached and dyed
white and a filling of polyester fiberfill. The pillows, except for the body pillow, SKU#
11135A-MBP-WHITE, are sewn with self-fabric piping measuring less than 3 millimeters wide along the
edges. SKU# 11135A-MBP-WHITE is sewn with a knife edge. The Down Alternative Firm Density pillows
come in the following shapes and sizes:
Item Description SKU # Finished Size Product #
1 Med Body Pillow White 11135A-MBP-WHITE 20 × 72 inches 25DALTP01
2 12 × 21 White 11135A-12X21-WHITE 12 × 21 inches 25DALTP02
3 14 × 30 White 11135A-14X30-WHITE 14 × 30 inches 25DALTP03
4 14 × 40 White 11135A-14X40-WHITE 14 × 40 inches 25DALTP04
5 16 White 11135A-16-WHITE 16 × 16 inches 25DALTP05
6 18 White 11135A-18-WHITE 18 × 18 inches 25DALTP06
7 20 White 11135A-20-WHITE 20 × 20 inches 25DALTP07
8 22 White 11135A-22-WHITE 22 × 22 inches 25DALTP08
9 24 White 11135A-24-WHITE 24 × 24 inches 25DALTP09
10 26 White 11135A-26-WHITE 26 × 26 inches 25DALTP10
11 Bolster White 11135A-BOL-WHITE 8 × 20 inches 25DALTP11
12 Boudoir White 11135A-BSML-WHITE 12 × 16 inches 25DALTP12
13 Neckroll White 11135A-NR-WHITE 6 × 16 inches 25DALTP13
14 Reading Wedge Lrg White 11135A-RWL-WHITE 36 × 18 × 12 inches 25DALTP14
15 Reading Wedge Med White 11135A-RWM-WHITE 20 × 15 × 8 inches 25DALTP15
16 Boudoir Lrg White 11135A-BLG-WHITE 16 × 24 inches 25DALTP16
17 Boudoir Med White 11135A-BMED-WHITE 16 × 20 inches 25DALTP17
The manufacturing operations for the Down Alternative Firm Density pillows are as follows:
PAKISTAN:
Polyester fabric for the pillow shell and piping is woven.
Greige polyester shell and piping fabric is exported to China.
CHINA:
Polyester fiber fill and piping cord are manufactured.
Greige polyester shell fabric is bleached and dyed white.
Piping is formed.
Polyester shell fabric is cut and assembled into a pillow shell with piping by sewing.
Pillow shell is filled with polyester staple fiber and sewn closed.
Completed pillow insert 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
9404.90 Except for goods of subheading 9404.90 provided for in paragraph (e)(2) of
this section, the country of origin of a good classifiable under subheading
9404.90 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 19 CFR 102.21(b)(2) as “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,
For goods of HTSUS headings 6213 and 6214 and HTSUS subheadings 6117.10, 6302.22, 6302.29,
6302.52, 6302.53, 6302.59, 6302.92, 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;
(ii) If the country of origin cannot be determined under paragraph (e)(2)(i) of this section...the country
of origin is the country, territory, or insular possession in which the fabric comprising the good was
formed by a fabric-making process;
The pillows are classified under subheading 9404.90.20, Harmonized Tariff Schedule of the United States
(HTSUS), which is not included in the exceptions covered under paragraph (e)(2). As the fabric for the
pillows is formed in a single country, that is, Pakistan, as per the terms of the tariff shift requirement, country
of origin is conferred in Pakistan.
HOLDING:
The country of origin of the Down Alternative Firm Density pillow inserts is Pakistan in accordance with 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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division