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 pillow protector; 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 a
pillow protector which will be imported into the United States. Photographs and a technical diagram of the
item were submitted in lieu of a sample.
FACTS:
The item, identified as the “Cool Zzz™ Pillow Protector,” is made of 80 percent cotton and 20 percent
polyester woven fabric that is bleached and dyed white. The pillow protector features a knife-edge finish on
three sides and an invisible zipper closure on the fourth side. The pillow protector is packaged in a
polyethylene (PE) bag and sold at retail under The Company Store brand. The pillow protector is available in
the following SKU #s, Product #s and sizes:
Name SKU# Product Number Dimensions
Cool Zzz™ Pillow Protector Standard White 11124G-STD-White 25CZPP01 20 × 26 inch
Cool Zzz™ Pillow Protector Queen White 11124G-Q-White 25CZPP02 20 × 30 inch
Cool Zzz™ Pillow Protector King White 11124G-K-White 25CZPP03 20 × 36 inch
The manufacturing operations for the pillow protector are as follows:
PAKISTAN:
80 percent cotton and 20 percent polyester fabric is woven.
Woven fabric is exported to China
CHINA:
Zippers, labels and sewing thread are manufactured.
The 80 percent cotton and 20 percent polyester woven fabric is bleached and dyed.
The fabric is cut, sewn and assembled by sewing into a pillow protector.
Zipper is sewn into end of pillow protector.
Finished pillow protector 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withdrawn from warehouse, for consumption on or after July 1, 1996.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
6301 - 6306 Except for goods of heading 6302 through 6304 provided for in
paragraph(e)(2) of this section, the country of origin of a good classifiable
under heading 6301 through 6306 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.
Paragraph (e)(2) in pertinent part states,
(2) For goods of HTSUS headings 6213 and 6214 and HTSUS subheadings 6117.10, 6302.22,
6302.29, 6302.53, 6302.59, 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;
The pillow protectors are classified under subheading 6302.31, Harmonized Tariff Schedule of the United
States (HTSUS). As the subject pillow protectors are not classified among the paragraph (e)(2) exceptions to
the above tariff shift rules, paragraph (e)(2) is inapplicable. Therefore, in accordance with paragraph (e)(1),
as the fabric for the pillow protector is formed by the fabric-making process 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 pillow protector 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