OT:RR:NC:N2:350
Classification: 5811.00.3000
Mr. Ameet Shah
Culp Inc.
1823 Eastchester Dr
Highpoint, NC 27265
RE: The tariff classification and country of origin of two quilted mattress ticking fabrics; 19 CFR 102.21
(c)(5)
Dear Mr. Shah:
In your letter dated December 9, 2025, you requested a tariff classification and country of origin ruling on
two quilted mattress ticking fabrics.
FACTS:
In your original submission you forwarded two samples of the subject fabrics to our office, which are
identified as “FWQI VERLO CK9849” and “FWQI VERLO CK9881-1.” Based on your submission and
subsequent correspondence, we can ascertain that fabric FWQI VERLO CK9849 is composed of five layers
and fabric FWQI VERLO CK9881-1 is composed of six layers. Both fabrics are comprised wholly of
man-made fibers.
Our observations indicate that fabric FWQI VERLO CK9849 is approximately 43 mm thick and fabric FWQI
VERLO CK988-1-1 is approximately 57 mm thick. The fabrics will be produced in 88-inch widths and will
be used as mattress ticking.
A brief description pertaining to each layer of fabric is as follows:
FWQI VERLO CK9849:
Layer 1 - 480 g/m2 circular knit fabric, produced in the United States or Turkey
Layer 2 - 590 g/m2 foam layer, produced in the Dominican Republic
Layer 3 - 25 g/m2 fire resistant layer, produced in the Dominican Republic
Layer 4 - 230 g/m2 fire resistant layer, produced in the United States
Layer 5 - 30 g/m2 nonwoven backing layer, produced in the Dominican Republic
FWQI VERLO CK9881-1:
Layer 1 - 480 g/m2, circular knit fabric, produced in the United States or Turkey
Layer 2 - 590 g/m2 foam layer, produced in the Dominican Republic
Layer 3 - 230 g/m2 foam layer, produced in the Dominican Republic
Layer 4 - 25 g/m2 fire resistant layer, produced in the Dominican Republic
Layer 5 - 230 g/m2 fire resistant layer, produced in the United States
Layer 6 - 27 g/m2 nonwoven backing layer, produced in the Dominican Republic
All materials are then exported to Haiti where the manufacturing continues as follows:
FWQI VERLO CK9849 & FWQI VERLO CK9881-1:
Step 1 - All components loaded onto the quilting machine in Haiti
Step 2 - Quilting process begins loading materials into the quilting machine in Haiti
Step 3 - Quilting machine sews all components/layers together with a quilt pattern in Haiti
Step 4 - Quilting machine rolls the quilted fabric in preparation for packing in Haiti
CLASSIFICATION:
The applicable subheading for the quilted mattress ticking fabrics “FWQI VERLO CK9849” and “FWQI
VERLO CK9881-1” will be 5811.00.3000, Harmonized Tariff Schedule of the United States (“HTSUS”),
which provides for “Quilted textile products in the piece, composed of one or more layers of textiles
materials assembled with padding by stitching or otherwise, other than embroidery of heading 5810: Of
man-made fibers.” The rate of duty will be 8 percent ad valorem.
COUNTRY OF ORIGIN - LAW AND ANALYSIS:
Section 334 of the Uruguay Round Agreements Act (“URAA”) (codified at 19 USC 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.
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:
HTSUS Tariff shift and/or other requirements
5811
The country of origin of a good classifiable under heading 5811 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.
Since the quilted fabrics FWQI VERLO CK9849 and FWQI VERLO CK9881-1 are constructed from
multiple fabrics formed in various countries, 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 goods of heading 5609, 5807, 5811, 6213, 6214, 6301 through 6306, and 6308, and
subheadings 6209.20.5040, 6307.10, 6307.90, and 9404.90, 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 subject merchandise is not knit to shape and is excepted under heading 5811 regarding being wholly
assembled in a single country, Section 102.21 (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.”
The most important manufacturing process occurs at the time of the fabric making. Since the fabrics for the
quilted fabrics FWQI VERLO CK9849 and FWQI VERLO CK9881-1 are formed in various countries, and
no one fabric is more important than the other, the country of origin cannot be made based on the fabric
making process. As such, Section 102.21(c)(4) is inapplicable.
Paragraph (c)(5) states, “Where the country of origin of a textile or apparel product cannot be determined
under paragraph (c)(1), (2), (3) or (4) of this section, the country of origin of the good is the last country,
territory or insular possession in which an important assembly or manufacturing process occurred.”
Accordingly, in the case of the quilted fabrics FWQI VERLO CK9849 and FWQI VERLO CK9881-1, the
country of origin is conferred by the last country in which an important assembly or manufacturing process
occurred, that is, Haiti.
HOLDING:
The tariff classification for the quilted fabrics “FWQI VERLO CK9849” and “FWQI VERLO CK9881-1”
will be 5811.00.3000, HTSUS, and the country of origin is Haiti pursuant to 19 CFR 102.21(c)(5).
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
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 Code of Federal Regulations (19 CFR
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 Michael Capanna at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division