OT:RR:NC:N2:349
Ms. Amy Bo
Longxiang Vietnam Textile Making Company Limited
Factory B and part of factory A, Lot 31, Road No. 15B, Tan Duc Industrial Park, Tay Ninh Province
Duc Hoa Commune 850000
Vietnam
RE: Country of origin determination for a faux rabbit fur pillow; 19 CFR 102.21(c)(2); tariff shift
Dear Ms. Bo:
This is in reply to your letter dated April 23, 2026, requesting a country of origin determination for a faux
rabbit fur pillow, which will be imported into the United States. A photo has been submitted with your
request in lieu of a sample.
DPCI# 067-08-0299, described as a “Faux Rabbit Fur Pillow” is a decorative pillow with an outer shell of
100 percent polyester warp knit pile fabric that is stuffed with polyester fiber. This square pillow features a
long, shaggy faux fur pile fabric on both sides. The pillow is sewn along the edges with a knife edge finish.
The “Faux Fur Pillow” measures 20 x 20 inches and is marketed under the THRESHOLD™ brand sold at
Target stores.
The manufacturing operations for the faux rabbit fur pillow are as follows:
China:
Polyester faux rabbit fur fabric is knit.
Polyester faux rabbit fur fabric undergoes dyeing, washing, drying, napping, shearing, decating and tip
printing.
Polyester faux rabbit fur fabric is rolled and shipped to Vietnam.
Vietnam:
Loose polyester fiber filling and labels are manufactured.
Fabrics are cut into panels.
Panels are sewn into pillow shells, stuffed, and sewn closed with labels.
Finished faux fur rabbit pillows are inspected, packaged and shipped to the United States.
ISSUE:
What is 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withdrawn from warehouse, for consumption on or after July 1, 1996.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,
(2) 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;
(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 faux rabbit fur pillow is classifiable under subheading 9404.90.20, Harmonized Tariff Schedule of the
United States (HTSUS), and is not subject to paragraph (e)(2). The fabric comprising the pillow is formed in
China. As the fabric-making process occurs in a single country, that is, China, as per the terms of the tariff
shift requirement, country of origin is conferred in China.
HOLDING:
The country of origin of the “Faux Rabbit Fur Pillow,” DPCI# 067-08-0299, is 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 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