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 decorative pillow; 19 CFR 102.21(c)(2); tariff shift
Dear Ms. Daniels:
This is in reply to your letter dated April 19, 2026, submitted on behalf of your client, Crane USA Inc.,
requesting a country of origin determination for decorative pillows which will be imported into the United
States. Our office received a physical sample of Item CH-210DP-1 and photographs of Items CH-210DP-1,
CH210DP-2, CH-220DP-6, CH-200DP-3 and CH-220DP-2. The sample of Item CH-210DP-1 will be
retained by our office.
Item #CH-210DP-1, described as both the “Dune Reversible Decorative Pillow” and the “Sunrise
Two-Toned Pillow,” is a pillow consisting of a pillow insert covered with a lined decorative pillow cover
with a zipper closure. The pillow insert is made of a 100 percent cotton woven fabric shell that is stuffed
with 100 percent polyester microfill fiber. The decorative pillow cover is made of a compound 100 percent
cotton woven fabric. The underlying warp and weft are of undyed yarns in a plain weave construction.
Additional wefts of coarser, dyed, gimped yarns are inserted in bundles of 5 under every eighth warp. The
pillow cover is lined with a lightweight 100 percent cotton woven fabric. The cover is finished with a zipper
closure on one end, a knife edge finish on the opposite end and fringe on the two sides. The completed
pillow measures 20 × 20 inches. The item is imported for retail sale under the Dune Collection of the Crane
Home brand.
Item #CH-210DP-2, described as both the “Dune Aztec Decorative Pillow” and the “Tribal Sun Pillow,” is a
pillow consisting of a pillow insert covered with a lined decorative pillow cover with a zipper closure. The
pillow insert is made of a 100 percent cotton woven fabric shell that is stuffed with 100 percent polyester
microfill fiber. The decorative pillow cover is made of 100 percent cotton woven fabric. The face panel is
made from a rust-orange, yarn-dyed, woven fabric that is embroidered with a geometric tribal pattern. The
back panel is constructed of plain-woven fabric formed from dyed warp yarns and undyed weft yarns. The
pillow cover is lined with a lightweight 100 percent cotton woven fabric. The cover is finished with a zipper
closure on one side and knife edge finish on other three sides. The completed pillow measures 20 × 20
inches. The item is imported for retail sale under the Dune Collection of the Crane Home brand.
Item #CH-220DP-6, described as both the “Zen Decorative Pillow” and the “Forest Path Pillow,” is a pillow
consisting of a pillow insert covered with a lined decorative pillow cover with a zipper closure. The pillow
insert is made of a 100 percent cotton woven fabric shell that is stuffed with 100 percent polyester microfill
fiber. The decorative pillow cover is made of 100 percent cotton woven fabric. The face panel is woven
with creme-colored undyed yarns. The fabric is embroidered with dyed yarns in a rectangular checkered
pattern over the majority of the center third of the surface area. The back panel is constructed of plain-woven
fabric formed from undyed yarns. The pillow cover is lined with a lightweight 100 percent cotton woven
fabric. The cover is finished with a zipper closure on one side and knife edge finish on other three sides. The
completed pillow measures 20 × 20 inches. The item is imported for retail sale under the Zen Collection of
the Crane Home brand.
Item# CH-200DP-3, described as both the “Calm Decorative Pillow” and the “Ivory Chevron Pillow,” is a
pillow consisting of a pillow insert covered with a lined decorative pillow cover with a zipper closure. The
pillow insert is made of a 100 percent cotton woven shell that is stuffed with 100 percent polyester microfill
fiber. The decorative cover consists of a 56 percent wool, 39 percent cotton, and 5 percent other fiber face
panel that is woven in a chevron pattern with undyed cotton and wool yarns. The back panel of the cover is
constructed of a 100 percent cotton, cream-colored, undyed, plain-woven fabric. The pillow cover is lined
with a lightweight 100 percent cotton woven fabric. The cover is finished with a zipper closure on one side
and knife edge finish on other three sides. The completed pillow measures 18 × 18 inches. The item is
imported for retail sale under the Calm Collection of the Crane Home brand.
Item# CH-220DP-2, described as both the “Abstract Leaf Throw Pillow” and the “Abstract Leaf Throw
Pillow,” is a pillow consisting of a pillow insert covered with a lined decorative pillow cover with a zipper
closure. The pillow insert is made of a 100 percent cotton woven shell that is stuffed with 100 percent
polyester microfill fiber. The decorative cover consists of a 94 percent cotton and 6 percent wool face panel
that is woven with undyed cotton and wool yarns. The fabric is embroidered with dyed yarns in a repeating
abstract pattern. The back of the cover is constructed of a 100 percent cotton plain-weave fabric of dyed and
undyed yarns. The pillow cover is lined with a lightweight 100 percent cotton woven fabric. The cover is
finished with a zipper closure on one side and knife edge finish on other three sides. The completed pillow
measures 18 × 18 inches. The item is imported for retail sale under the Zen Collection of the Crane Home
brand.
The manufacturing operations for Item #CH-210DP-1, the “Dune Reversible Decorative Pillow,” are as
follows:
Uzbekistan:
Yarn is spun, singed, de-sized, scoured, and bleached.
Cotton yarn for pillow cover’s outer surface is dyed, washed and dried.
Cotton fabrics for the pillow cover and lining are woven.
Cotton fabric for the outer shell of the pillow insert is woven.
Polyester sewing thread is spun.
Front, back, lining, and insert shell fabrics are stented, softened, shrunk and inspected.
Rolls of finished cotton woven fabrics and spools of sewing thread are exported to India.
India:
Zipper, microfill and labels are manufactured.
Fabrics are cut into panels for pillow cover, lining and pillow shell.
Front and back panels, lining, and zipper are assembled by sewing to form the pillow cover.
Pillow insert shell is assembled and sewn on three sides with labels attached, filled with loose fibers,
and sewn closed.
Pillow insert is placed inside the cover, and the cover is zipped closed.
Finished pillows are packed, boxed, palletized and exported to the United States.
The manufacturing operations for Item #CH210DP-2, the “Dune Aztec Decorative Pillow,” are as follows:
Uzbekistan:
Yarn, including embroidery yarn, is spun, singed, de-sized, scoured and bleached.
Colored yarns for front and back panels are dyed, washed and dried.
Cotton fabrics for the pillow cover and lining are woven.
Cotton fabric for the outer shell of the pillow insert is woven.
Polyester sewing thread is spun.
Front, back, lining, and insert shell fabrics are stented, softened, shrunk and inspected.
Rolls of finished cotton woven fabrics and spools of embroidery yarn and sewing thread are exported
to India.
India:
Zipper, microfill, and labels are manufactured.
Fabrics are cut into panels for pillow cover, lining and pillow shell.
Front panel of the pillow cover is embroidered.
Front and back panels, lining, and zipper are assembled by sewing to form the pillow cover.
Pillow insert shell is sewn on three sides with labels attached, filled with loose fibers, and sewn closed.
Pillow insert is placed inside the cover, and the cover is zipped closed.
Finished decorative pillows are packed, boxed, palletized and exported to the United States.
The manufacturing operations for Item #CH-220DP-6, the “Zen Decorative Pillow,” are as follows:
Uzbekistan:
Yarn, including embroidery yarn, is spun, singed, de-sized, scoured and bleached.
Cotton fabrics for the pillow cover and lining are woven.
Cotton fabric for the outer shell of the pillow insert is woven.
Polyester sewing thread is spun.
Embroidery yarn is dyed.
Front, back, lining, and shell fabrics are stented, softened, shrunk and inspected.
Rolls of finished cotton woven fabrics and spools of embroidery yarn and sewing thread are exported
to India.
India:
Zipper, microfill, and labels are manufactured.
Fabrics are cut into panels for pillow cover, lining and pillow shell.
Front panel of the pillow cover is embroidered.
Front and back panels, lining, and zipper are assembled by sewing to form the pillow cover.
Pillow insert shell is sewn on three sides with labels attached, filled with loose fibers, and sewn closed.
Pillow insert is placed inside the cover, and the cover is zipped closed.
Finished decorative pillows are packed, boxed, palletized and exported to the United States.
The manufacturing operations for Item# CH-200DP-3, the “Calm Decorative Pillow” are as follows:
Uzbekistan:
Yarn is spun, singed, de-sized, scoured and bleached.
Fabric for front panel of the pillow cover is woven.
Cotton fabric for the back panel of the pillow cover, lining and outer shell of pillow insert is woven.
Polyester sewing thread is spun.
Front, back, lining, and shell fabrics are stented, softened, shrunk and inspected.
Rolls of finished fabrics for pillow covers, lining and outer shell for pillow insert and spools of sewing
thread are exported to India.
India:
Zipper, microfill and labels are manufactured.
Fabrics are cut into panels for pillow cover, lining and pillow shell.
Front and back panels, lining, and zipper are assembled by sewing into a finished pillow cover.
Pillow insert shell is sewn on three sides with labels attached, filled with loose fibers, and sewn closed.
Pillow insert is placed inside the cover and, the cover is zipped closed.
Finished decorative pillows are packed, boxed, palletized and exported to the United States.
The manufacturing operations for Item# CH-220DP-2 the “Abstract Leaf Throw Pillow” are as follows:
Uzbekistan:
Yarn, including embroidery yarn, is spun, singed, de-sized, scoured, bleached, dyed, washed and dried.
Cotton/wool fabric for front panel of the pillow cover is woven.
Cotton yarn for the back panel fabric of the pillow cover is woven from dyed and undyed yarns.
Cotton fabric for the pillow insert shell and lining is woven.
Polyester sewing thread is spun.
Front, back, lining, and shell fabrics are stented, softened, shrunk and inspected.
Rolls of finished fabrics for pillow covers, lining and outer shell for pillow insert and spools of thread
and embroidery yarn are exported to India.
India:
Zipper, microfill and labels are manufactured.
Fabrics are cut into panels for pillow cover, lining and pillow shell.
Front panel of the pillow cover is embroidered.
Front and back panels, lining and zipper are assembled by sewing into a finished pillow cover.
Pillow insert shell is sewn on three sides, filled with loose fibers, and sewn closed.
Pillow insert is placed inside the cover and, the cover is zipped closed.
Finished decorative pillows are packed, boxed, palletized 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 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, 6302.52,
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 decorative pillows are not classified in a subheading subject to paragraph (e)(2) and all of the fabrics
comprising the decorative pillows are formed in Uzbekistan. As the fabric-making process occurs in a single
country, that is, Uzbekistan, as per the terms of the tariff shift requirement, country of origin is conferred in
Uzbekistan.
HOLDING:
The country of origin for Item #CH-210DP-1, the “Dune Reversible Decorative Pillow”; Item #CH-210DP-2,
the “Dune Aztec Decorative Pillow”; Item #CH-220DP-6, the “Zen Decorative Pillow”; Item #CH-200DP-3,
the “Calm Decorative Pillow”; and Item #CH-220DP-2, the “Abstract Leaf Throw Pillow,” is Uzbekistan,
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 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 P. Forkan
Director
National Commodity Specialist Division