OT:RR:NC:N2:350
Emily Zhang
3H Medical (Thailand) Co., Ltd.
60 Moo 3, Hang Sung Subdistrict Nong Yai District
Chon Buri 20190
Thailand
RE: The country of origin of two bandage fabrics; 19 CFR 102.21(c)(2), tariff shift; 19 CFR 102.21(c)(4)
Dear Ms. Zhang:
In your letter dated February 6, 2026, you requested a tariff classification and country of origin ruling on two
bandage fabrics. Samples of the two bandages were submitted and will be retained by our office.
FACTS:
In your original submission you submitted two samples of OK Tape brand cohesive bandages to our office,
which are identified as “Woven cohesive bandage” and “Non-woven cohesive bandage.” These items will be
referred to as the woven bandage and nonwoven bandage, respectively. Based on your submission and
subsequent correspondence, we can ascertain that the woven bandage is of woven construction, composed of
95 percent cotton and 5 percent spandex, and that the nonwoven bandage is comprised of three layers
constructed of a nonwoven layer of polypropylene (“PP”) fibers, a mesh layer of knitted polyester, and
laid-in spandex yarns. The nonwoven bandage is composed of 62.5 percent (PP), 21 percent polyester and
16.5 percent spandex. The woven bandage has been coated with uncolored synthetic rubber and the
nonwoven bandage has been coated with latex. The fabrics are cut to 2 inches in width by 14.8 feet in length
and packaged for retail sale.
You have presented four different prospective origin scenarios, one will apply to the woven bandage and
three will apply to the nonwoven bandage.
The manufacturing operations for the woven bandage are as follows:
Scenario 1
China:
Greige cotton fabric is woven, dyed and combined with elastic spandex yarns into a finished woven fabric.
Finished fabric is exported in rolls in Thailand.
Thailand:
Fabric is coated with rubber, cured and dried.
Fabric is cut to size and packaged for retail sale.
Finished product is packaged in cartons and exported to the United States.
The manufacturing operations for the nonwoven bandages are as follows:
Scenario 2
China:
Polypropylene nonwoven fabric, polyester mesh fabric, and the elastic spandex yarns are each formed and
combined into finished bonded nonwoven fabric.
Finished fabric is exported in rolls to Thailand.
Thailand:
Fabric is coated with latex, cured and dried.
Fabric is cut to size and packaged for retail sale.
Finished product is packaged in cartons and exported to the United States.
Scenario 3
China:
Polypropylene nonwoven fabric, polyester mesh fabric, and the elastic spandex yarns are each formed.
Nonwoven fabric, mesh fabric in rolls and the elastic yarns spooled are exported to Thailand.
Thailand
Polypropylene nonwoven fabric, polyester mesh fabric, and the elastic spandex yarns are combined into a
finished bonded nonwoven fabric.
Fabric is coated with latex, cured and dried.
Fabric is cut to size and packaged for retail sale.
Finished product is packaged in cartons and exported to the United States.
Scenario 4
China
Polypropylene nonwoven fabric and polyester mesh fabric are each formed and bonded together.
Elastic spandex yarns is formed.
Bonded nonwoven fabric in rolls and elastic yarns spooled are exported to Thailand.
Thailand
Elastic spandex yarns are inserted into the two layer bonded nonwoven fabric into finished bonded nonwoven
fabric.
Fabric is coated with latex, cured and dried.
Fabric is cut to size and packaged for retail sale.
Finished product is packaged in cartons and exported to the United States.
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:
HTSUS Tariff shift and/or other requirements
5906-5907 (1) Except for fabric of wool or of fine animal hair, a change from
greige fabric of heading 5906 through 5907 to finished fabric of
heading 5906 through 5907 by both dyeing and printing when
accompanied by two or more of the following finishing operations:
bleaching, shrinking, fulling, napping, decating, permanent stiffening,
weighting, permanent embossing, or moireing; or,
(2) If the country of origin cannot be determined under (1) above, a
change to heading 5906 through 5907 from any other chapter, except
from heading 5007, 5111 through 5113, 5208 through 5212, 5309
5602-5603 (1) Except for fabric of wool or of fine animal hair, a change from
greige fabric of heading 5602 through 5603 to finished fabric of
heading 5602 through 5603 by both dyeing and printing when
accompanied by two or more of the following finishing operations:
bleaching, shrinking, fulling, napping, decating, permanent stiffening,
weighting, permanent embossing, or moireing; or
(2) If the country of origin cannot be determined under (1) above, a
change to heading 5602 through 5603 from any heading outside that
group, provided that the change is the result of 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.
The woven fabric, subject to origin in scenario 1 would be classifiable under heading 5906 of the
Harmonized Tariff Schedule of the United States (“HTSUS”) as a rubberized textile fabric. In scenario 1,
subject to paragraph (e)(1) above, you state the woven fabric is only dyed and no additional finishing p
rocesses are performed, therefore paragraph (e)(1) is inapplicable. In scenario 1, subject to paragraph (e)(2)
above, while there is a tariff shift to heading 5906, it is from the excepted headings of 5208 through 5212.
Therefore, paragraph (c)(2) is inapplicable for determining the country of origin of the woven bandage in
scenario 1. We proceed to paragraph (c)(3) for scenario 1.
The nonwoven fabric, subject to origin in scenario 2, scenario 3, and scenario 4 would be classifiable under
heading 5603, HTSUS, as a nonwoven fabric. In each of these cases, subject to paragraph (e)(1) above, no
dyeing, printing or other finishing operations occurred, therefore, paragraph (e)(1) is inapplicable. In each of
these cases, subject to paragraph (e)(2) above, the nonwoven fabric was formed in a single country, that is
China, as per the terms of the tariff shift requirement, the country of origin of each nonwoven bandage in
scenario 2, scenario 3, and scenario 4 is China.
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 woven bandages in scenario 1 are not knit to shape and classified in headings excepted from
paragraph
(c)(3)(ii), Section 102.21(c)(3) for is inapplicable. We proceed to paragraph (c)(4).
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.”
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 subject merchandise, Customs and Border Protection has generally held that the most
important assembly or manufacturing process, as it pertains to textiles, is the fabric-making process as
defined in Section 102.21 (b) (2). Since the fabric-making process concerning the woven bandages occurs in
China, the country of origin is conferred as the China.
HOLDING:
The country of origin of the subject “Woven cohesive bandage” is China pursuant to 19 CFR 102.21(c)(4)
and the country of origin of the subject “Non-woven cohesive bandage” is also China pursuant to 19 CFR
102.21(c)(2).
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is 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. If the facts are modified in any way, or if the goods do not conform to
these facts at the time of importation, you should bring this to the attention of 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)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division