OT:RR:NC:N3:351
Ms. Jo-Anne Daniels
Jo-Anne Daniels DBA Trade Resources & Associates
230-B Tyson Avenue
Paris, TN 38242
RE: Country of origin determination for a playmat, storage bin, and swaddling wraps with drawstring bag; 19
CFR 102.21(c)(2) and 19 CFR 102.21(c)(4)
Dear Ms. Daniels:
In your letter, dated February 2, 2026, you requested a country of origin determination on behalf of your
client, Crane USA, Inc, for three items. Samples of the product were provided to this office and will be
retained for training purposes.
Sample 1, Item #BC-100PM, described as a “Parker Quilted Play Mat,” is a quilted mat intended to be placed
on the floor or other surface for a baby to lay on. The mat consists of three layers: a single layer of 100
percent polyester batting sheet is sandwiched between two layers of 100 percent cotton woven sateen
fabric. The three layers are quilted together. The round shaped mat measures 40 inches in diameter and is
finished with tassels along the perimeter. The mat is imported without toys such as a mirror, rattle, crinkle
paper toys, or a squeaker. You state the item is available in five additional style numbers, each with its own
SKU number and style name: BC-110PM, “Ezra Quilted Playmat”; BC-120PM, “Kendi Quilted Play Mat”;
BC-130PM, “Caspian Quilted Play Mat”; BC180PM, “Willow Quilted Play Mat”; and BC-190PM-2,
“Charlie Farmhouse Quilted Play Mat.”
Sample 2, Item #BC-120SB-2, described as a “Kendi Safari Animal Nursery Storage Carry Bag,” is a textile
storage bin designed and intended to store items. The open top, round-shaped bin is constructed of 100
percent cotton woven, printed canvas fabric. The top rim of the bin is folded over and finished with a 1 ¼
inch wide 100 percent cotton woven binding. The unlined storage bin measures 13 inches in diameter by 12
inches in height and features two rectangular slit handles. You state the item is available in two additional
styles, each with its own SKU number and style name: BC-110SB, “Ezra Woodland Animal Nursery
Storage Carry Bag,” and BC-180SB-1, “Willow Boho Batik Nursery Storage Carry Bag.”
Sample 3, Item #BC-100SWS, described as a “Parker 2-Piece Swaddle Wraps,” is a set of two multipurpose
textile items packaged inside a self-fabric textile drawstring bag. Both wraps are designed to be used as an
on-the-go changing pad, to wrap and snuggle a baby, while nursing, or to provide shade in a stroller. Each
multi-use item is composed of two layers of lightweight 100 percent cotton woven muslin, printed fabric.
Each item measures 47 x 47 inches and is hemmed on all four sides. The swaddle blankets are washable and
reusable. Both wraps will be packaged inside a self-fabric bag. The square-shaped bag measures 10 ½ by 10
½ inches and is sewn on three sides. The bag is unlined with a drawstring-type closure using narrow woven
fabric (instead of a drawstring) to cinch the bag closed. You state the item is available in ten additional
styles, each with its own SKU number and style name: BC-100SWS-2, “Parker 2pc Butterfly/Rainbow
Swaddle Set”; BC-110SWS, “Ezra 2pc Swaddle Wraps (Copper Dash & Ezra Print)”; BC-120SWS, “Kendi
2pc Swaddle Wraps”; BC-130SWS, “Caspian 2pc Swaddle Wraps”; BC-190SWS-1, “Charlie Tractor/Dot
2pc Swaddle Set”; BC-190SWS-2, “Charlie Goose/Check 2pc Set”; BC-160SWS-1, “Cove 3pc Beach Life
Swaddle”; BC-160SWS-2,” Cove 3pc Sea Life Swaddle”; BC-150SW-1, “Avery Bunny Swaddle Blanket”;
BC-150SW-2, “Avery Poppy Swaddle Blanket.”
You state the manufacturing operations for the playmat, storage bin, swaddle wraps, and drawstring bag are
as follows:
Uzbekistan:
Playmat:
Cotton is grown and yarn is spun.
100 percent cotton griege top layer fabric is woven.
100 percent cotton griege bottom layer is woven.
Griege top layer fabric undergoes pre-treatment processes including, singeing, desizing, scouring,
bleaching, and mercerization, drying, printing, heat curing or steaming, washing, final drying, and
finished through stentering drying, softening, and shrinkage control prior to final inspection.
Griege bottom layer fabric undergoes pre-treatment processes including, singeing, desizing, scouring,
bleaching, and mercerization, drying, solid dying, heat curing or steaming, washing, final drying, and
finished through stentering drying, softening, and shrinkage control prior to final inspection.
100 percent polyester thread is produced
Polyester thread on cones and finished cotton printed and dyed fabric on rolls are shipped to India.
Storage Bin:
Cotton is grown and yarn is spun.
100 percent cotton griege fabric is woven.
Griege fabric undergoes pre-treatment processes including, singeing, desizing, scouring, bleaching, and
mercerization, drying, printing, heat curing or steaming, washing, final drying and finished through
stentering drying, softening, and shrinkage control prior to final inspection.
100 percent polyester thread is produced.
Polyester thread on cones and finished cotton printed fabric on rolls are shipped to India.
Swaddle Wraps and Drawstring bag:
Cotton is grown and yarn is spun.
100 percent cotton greige muslin fabric is woven
Greige muslin fabric undergoes pre-treatment processes including singeing, desizing, scouring,
bleaching, and mercerization, drying and preparing for two-layer formation. Once aligned and tacked,
the fabric is either engraved with a design or digitally printed, then heat-cured, washed, and finished
through stentering drying, softening, and shrinkage control prior to final inspection.
100 percent polyester thread is produced.
Polyester thread on cones and finished cotton printed fabric on rolls are shipped to India.
India:
Playmat:
100 percent cotton tassels are produced.
100 percent polyester batting sheet is produced.
Fabric and tassels are cut.
Fabric and batting sheet are quilted together.
Tassels are sewn around the edges to finish the playmat.
Completed playmat is inspected, attached with sewing label, hangtag, and packaged for export to the
United States.
Storage Bin:
100 percent cotton binding tape is woven.
Fabric and binding tape are cut and sewn to create a storage bin.
The storage bin is packaged and shipped to the United States.
Swaddle Wraps and Drawstring Bag:
Fabric is cut and sewn to create a wrap and drawstring bag.
Two wraps are packaged in a drawstring bag and shipped 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
playmat, storage bin, swaddle wraps, and drawstring bag are 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
6307.90 The country of origin of a good classifiable under subheading 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 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.
As the fabric for the swaddle wraps and drawstring bag are formed by the fabric-making process in a single
country, that is Uzbekistan, as per the terms of the tariff shift requirement, the country of origin for the
swaddle wraps and drawstring bag is conferred in Uzbekistan.
The storage bin is comprised of two fabrics formed in two different countries. The main body fabric is
woven in Uzbekistan, and the binding tape is woven in India.
Section 102.21(c), "General Rules," inter alia, state the requirements or conditions of Sections 102.12
through 102.19, where appropriate, are applicable when determining origin under Section 102.21(c)(1)
through (5). Section 102.13 "De Minimis," states the following, in pertinent part:
(c) Foreign components or materials that do not undergo the applicable change in tariff classification
set out in Section 102.21 or satisfy the other applicable requirements of that section when
incorporated into a textile or apparel product covered by that Section shall be disregarded in
determining the country of origin of the good if the total weight of those components or materials is
not more than 7 percent of the total weight of the good.
As you have stated, since the binding tape is not more than 7 percent of the total weight of the finished
storage bin, the binding tape is disregarded when determining the country of origin. Accordingly, the storage
bin complies with the terms of the tariff shift rule for heading 6307, HTSUS; the country of origin is
conferred by the single country in which the main body fabric comprising the storage bin was formed by the
fabric-making process. Hence, the country of origin of the storage bin is Uzbekistan.
As the fabrics comprising the playmat are formed in more than one country (face and backing fabric is
produced in Uzbekistan and batting sheet is produced in India). 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 play mat, 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).
The playmat consists of two outer shell fabrics (woven in Uzbekistan) and a batting sheet fabric (formed in
India). While all the fabrics are important to the construction of the playmat, in this case, it is the outer shell
fabrics that are most important as they provide the aesthetic appeal to the item. Accordingly, the
fabric-making process in Uzbekistan, where the outer shell fabrics are formed, constitutes the most important
manufacturing process and the country of origin of the playmat is Uzbekistan.
HOLDING:
The country of origin of the swaddle wraps, drawstring bag, and storage bin is Uzbekistan, pursuant to 19
CFR 102.21(c)(2).
The country of origin of the playmat is Uzbekistan 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 Kristine Dodge at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division