OT:RR:NC:N2:349
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 quilted changing pad cover; 19 CFR 102.21(c)(5); last country
where an important assembly or manufacturing process occurred
Dear Ms. Daniels:
This is in reply to your letter dated February 2, 2026, requesting a country of origin determination on behalf
of your client, Crane USA Inc., for a fitted changing pad cover, which will be imported into the United
States. A sample was submitted and will be disposed of by our office.
The submitted sample, Item #BC-100CPC-4, described as a "Parker Quilted Change Pad Cover - Floral," is a
cover designed to fit over a standard rectangular shaped infant changing pad, sold separately. The top of the
changing pad cover, when in use, is comprised of three layers: a face layer of 100 percent cotton sateen,
printed, fabric; a middle layer of 100 percent polyester nonwoven batting; and a backing of 100 percent
cotton cambric woven fabric. The three layers are quilted together. The skirt that holds the cover in place,
made of the printed sateen fabric, has a tunneled elasticized edge. The changing pad cover does not contain
any embroidery, lace, braid, edging, trimming, piping or applique work and measures 32 x 16 inches. It is
packaged for retail sale in a self-fabric bag featuring hook-and-loop and tie closures and a “Crane Baby”
label affixed to the front face. The changing pad cover is available in eight additional prints and SKU #s:
SKU# Item Description
BC-100CPC-3 Parker Quilted Change Pad Cover - Leaf
BC-110CPC-3 Ezra Quilted Change Pad Cover - Woodland
BC-120CPC Kendi Quilted Change Pad Cover - Safari
BC-130CPC Caspian Quilted Change Pad Cover - Whale
BC-150CPC-2 Organic Cotton Check Changing Pad
BC-180CPC Willow Quilted Change Pad Cover - Batik
BC-190CPC-1 Charlie Farmhouse Quilted Plaid Change Pad Cover
BC-190CPC-2 Charlie Farmhouse Quilted Change Pad Cover
The manufacturing operations for the quilted fitted change pad covers are as follows:
Uzbekistan:
Raw cotton is grown, ginned, cleaned, carded, and combed.
Fibers are spun into yarn.
Greige 100 percent cotton sateen fabric is woven.
Greige 100 percent cotton cambric fabric is woven.
100 percent polyester sewing thread is produced.
Greige sateen fabric undergoes singeing, desizing, scouring, bleaching, and mercerization, drying,
printing, heat curing or steaming, washing, stentering, softening, shrinkage control and final inspection.
Greige cotton cambric fabric undergoes singeing, desizing, scouring and bleaching.
Polyester thread, cotton sateen fabric, and cotton cambric fabric are shipped in spools and rolls to
India.
India:
Woven elastic band, nonwoven batting and hook and loop closure are formed.
Printed cotton sateen, nonwoven batting and cotton cambric fabrics are cut into panels, layered and
quilted together.
Sateen skirt fabric is cut, sewn and assembled to quilted panel.
Elastic is sewn in the hem around the edges.
Labels are attached by sewing.
Cotton sateen woven fabric is cut and assembled by sewing into self-fabric bags with both a
hook-and-loop and self-tie closure.
Fitted quilted changing pad covers are folded and packaged inside a self-fabric bag and wrapped with a
ribbon threaded through a front and back tile card.
Finished changing pad covers are 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)(1) 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,
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;
Based on the information provided in your letter, the Crane Baby Changing Pad Cover is classified under
subheading 6304.92, Harmonized Tariff Schedule of the United States (HTSUS). Subheading 6304.92,
HTSUS, is not listed in paragraph (e)(2); therefore, paragraph (e)(2) is not applicable. As the changing pad
cover is comprised of fabric sourced from more than one country, i.e., the top layer and bottom layer are
formed in Uzbekistan and the batting fabric and narrow woven elasticized fabrics are formed in India, there is
no single country in which the fabric was formed; therefore, the tariff shift under paragraph (e)(1) is not
applicable. Accordingly, Section 102.21(c)(2) is not applicable.
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 comprised of fabrics that are knit to shape, and heading 6304, HTSUS, is
excepted under provision (ii), Section 102.21 (c)(3) is inapplicable.
Paragraph (c)(4) states that, "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 changing pad cover, the fabric-making process constitutes the most important manufacturing
process. See NY E80405 (May 14, 1999), NY H85550 (Sept. 4, 2001) and Headquarters Ruling Letter
(“HQ”) 959256 (June 20, 1996). Since the fabric for the changing pad is formed in two countries, a single
country of origin determination cannot be made based on Section 102.21(c)(4).
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 subject fitted changing pad cover, the country of origin is conferred by the last
country in which an important assembly or manufacturing process occurred, that is, India.
HOLDING:
The country of origin of the Crane Baby Crib Fitted Sheet is India 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 Kim Wachtel at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division