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; 19 CFR 102.21(c)(4); most important assembly or
manufacturing process
Dear Ms. Shan:
This is in reply to your letter dated January 28, 2026, requesting a country of origin determination for a
pillow which will be imported into the United States. Photographs and a specification sheet were provided in
lieu of a sample.
FACTS:
The subject merchandise, described as the “Cool Zzz™ Deluxe Pillow” is a down alternative bed pillow
consisting of an outer shell of 100 percent cotton woven fabric, filling of 100 percent polyester fiberfill and
an inner lining of 75 percent nylon and 25 percent polyester woven fabric with phase change material (PCM)
cool coat printing. The pillow includes self-fabric piping around the edges of the four sides. The pillow will
be available in the following SKU#s:
Name SKU Product Number Dimensions
Cool Zzz Deluxe Pillow 11190-STD-White CLZPLW01 20 × 26 inches
Standard White
Cool Zzz Deluxe Pillow 11190-Q-White CLZPLW02 20 × 30 inches
Queen White
Cool Zzz Deluxe Pillow 11190-K-White CLZPLW03 20 × 36 inches
King White
The manufacturing operations for the Cool Zzz™ Deluxe Pillow are as follows:
PAKISTAN:
100 percent cotton fabric for pillow shell is woven.
Cotton woven greige fabric is exported to China.
CHINA:
75 percent nylon and 25 percent polyester lining fabric is woven and treated with PCM cool coat printing.
Piping cord and polyester staple fiber for filling are formed.
Cotton fabric is bleached and dyed.
Piping is formed with piping cord and cotton fabric.
Cotton fabric is cut and assembled into a lined pillow shell with piping by sewing.
Cotton pillow shell is filled with polyester fiber and sewn closed.
Completed pillow 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withdrawn from warehouse, for consumption on or after July 1, 1996.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 pillow is classified under subheading 9404.90.10, Harmonized Tariff Schedule of the United States
(HTSUS), which is not included in the exceptions covered under paragraph (e)(2). However, as the fabric for
the pillow is formed by the fabric-making process in more than a single country, classification cannot be
found under the above tariff shift rule and, therefore, 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 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 subject merchandise is not knit to shape and subheading 9404.90 is included in the subparagraph (ii)
exceptions, 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 pillows, the fabric-making process of the pillow’s outer shell constitutes the most
important assembly process. It is the outer shell which actually forms the merchandise. Therefore, the
country of origin of the subject pillows is where the fabric forming the outer shell is formed, that is, Pakistan.
HOLDING:
The country of origin of the Cool Zzz™ Deluxe Pillow 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