OT:RR:NC:N3:351
Mr. Paul Anderson
The Anderson Law Firm, LLC
100 South Saunders Road, Suite 150
Lake Forest, IL 60045
RE: Country of origin determination for a furniture moving blanket; 19 CFR 102.21(c)(5)
Dear Mr. Anderson:
In your letter, dated January 16, 2026, you requested a ruling on the country of origin of a moving blanket, on
behalf of your client, Pull’R Holding Company, LLC. In lieu of a sample, photographs of the item were
provided with your request.
The item, described as a “HDX Double-Sided Moving Blanket,” is a furniture moving blanket intended to
protect furniture, wall hangings, lamps and similar items, from damage while moving. The blanket consists
of three layers quilted together: a 100 percent polyester woven dyed face fabric; a recycled nonwoven felt
batting middle layer, and a 100 percent polypropylene nonwoven dyed backing fabric. You state the felt
batting is composed of cotton and various other fibers. The rectangular shaped blanket is bound along the
edges with a 100 percent polypropylene nonwoven fabric. The “HDX Double-Sided Moving Blanket” is
available in the following two sizes and SKU #: #1015151200, Premium (72 x 80 inches) and #1015081408,
Extra-Large Premium (72 by 106 inches). The blanket is not washable.
You state the manufacturing operations for the moving blanket are as follows:
CHINA:
Face fabric: 100 percent polyester fabric is woven and shipped in rolls to Thailand.
Middle layer: Nonwoven felt batting is produced from sorting fibers from scraps, clothing and other
discarded cotton and various other fiber-based products and shipped in rolls to Thailand.
THAILAND:
Backing fabric: 100 percent polypropylene nonwoven fabric is produced.
100 percent polypropylene nonwoven binding fabric is produced.
Polyester sewing thread, label, hangtag, polyethylene (PE) bags and carton packaging are produced.
Face fabric, nonwoven batting, and back fabric are cut and quilted together.
Binding fabric is sewn around the edges to finish the blanket.
Completed moving blanket is inspected, attached with sewing label, hangtag, and packaged for export
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1994, provided rules of origin for textiles and apparel entered, or withdrawn from warehouse for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:”
Paragraph (e)(1) provides the rules used to determine the country of origin of a textile or apparel product
under paragraph (c)(2) of this section. These rules are dependent on the classification of the good. The
moving blanket is classified under subheading 6307.90.9891, Harmonized Tariff Schedule of the United
States (HTSUS).
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
6307 The country of origin of a good classifiable under 6307.90 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 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.”
As the fabrics comprising the moving blanket are formed in more than one country (face fabric and felt
batting is produced in China and the back fabric is formed in Thailand). 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 neither knit to shape, and subheading 6307.90 is excepted from provision (ii),
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.”
In the case of the subject merchandise, the most important manufacturing process occurs at the time of fabric
making. Basing the country-of-origin determination on the fabric making process, and not the assembly
process, carries out the clear intent of Section 334 as expressed in Section 334 (b)(2) and Part 102.21(c)(2).
As the fabrics for the subject moving blanket are formed in more than one country, and no one fabric can be
considered more important in this case, Section 102.21(c)(4) is inapplicable.
Paragraph(c)(5) states that “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 subject moving blanket, the country of origin is conferred by the last country
in which an important assembly or manufacturing process occurred, that is Thailand.
HOLDING:
The country of origin of the moving blanket is Thailand pursuant to 19 CFR 102.21(c)(5).
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 Kristine Dodge at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division