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 a duvet; 19 CFR 102.21(c)(4); most important assembly or
manufacturing process
Dear Ms. Shan:
This is in reply to your letter dated December 27, 2025, requesting a country of origin determination for a
duvet which will be imported into the United States. Photographs and a specification sheet were submitted in
lieu of a sample.
FACTS:
The subject merchandise is a quilted duvet described as the “Cool Zzz™ CMF.” The duvet is constructed
with an outer shell of 100 percent cotton woven fabric, filling of 100 percent polyester fiber, and a lining of
75 percent nylon and 25 percent polyester woven phase change material (PCM) fabric. The edges are
finished with self-fabric piping. Each corner includes a self-fabric exterior corner loop to secure the duvet to
a duvet cover. The duvet may be imported under the following sizes and SKU numbers:
Name SKU Product Number
Cool Zzz™ CMF Twin White 11197-T-WHITE CZZDT01
Cool Zzz™ CMF Twin XL White 11197-TXL-WHITE CZZDTXL02
Cool Zzz™ CMF Full White 11197-F-WHITE CZZDF03
Cool Zzz™ CMF Queen White 11197-Q-WHITE CZZDQ04
Cool Zzz™ CMF King White 11197-K-WHITE CZZDK05
The manufacturing operations for the duvet are as follows:
PAKISTAN:
100 percent cotton shell fabric is woven.
Greige cotton shell fabric is exported to China.
CHINA:
75 percent nylon and 25 percent polyester lining fabric is woven and treated with PCM cool coat
printing.
Polyester fiber for filling is formed.
Cording for piping is formed.
Greige cotton shell fabric is bleached and dyed.
Cording is covered with self-fabric to form piping.
Self-fabric corner loops are formed.
Fabrics are cut and assembled by sewing into a duvet shell with lining on one of the sides, self-fabric
piping along the edges and self-fabric corner loops.
Duvet shell is stuffed with polyester fiber, sewn closed and quilted.
Finished duvet 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 (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1994, provided rules of origin for textiles and apparel entered, or withdrawn from warehouse for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:”
The duvet is classified under subheading 9404.40.10, Harmonized Tariff Schedule of the United States
(HTSUS). Prior to 2022, the corresponding HTSUS to subheading 9404.40.10 was subheading 9404.90.80.
Section 102.21 has not been updated with the current tariff subheadings. Therefore, we follow the rule
corresponding to the prior classification, below. See New York Ruling Letter (“NY”) N338830.
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;
Subheading 9404.90.80, HTSUS, is not provided for under paragraph (e)(2), therefore, paragraph (e)(2) is not
applicable. As the duvet is comprised of fabric sourced from more than one country, i.e., the outer shell is
formed by the fabric-making process in Pakistan and the lining is formed by the fabric-making process in
China, there is no single country in which the fabric is formed; therefore, the tariff shift under paragraph
(e)(1) is not applicable. Accordingly, Section 102.21(c)(2) is not applicable to this merchandise.
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.
As the duvets are not knit to shape and subheading 9404.90, HTSUS, is excepted from provision (ii),
paragraph (c)(3) is inapplicable.
Paragraph (c)(4) states, “Where the country of origin of a textile or apparel product cannot be determined
under paragraph (c) (1), (2) or (3) of this section, the country of origin of the good is the single country,
territory, or insular possession in which the most important assembly or manufacturing process occurred.”
In the case of the subject duvets, the fabric-making process of the duvet’s outer shell constitutes the most
important assembly process. See HQ 959813. It is the outer shell which actually forms the merchandise.
Therefore, the country of origin of the subject duvets is where the fabric forming the outer shell is formed,
that is, Pakistan.
HOLDING:
The country of origin of the duvets is Pakistan pursuant to 19 CFR 102.21(c)(4).
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