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 throw; 19 CFR 102.21(c)(5); last country where an
important assembly or manufacturing process occurred
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 throw, which will be imported into the United States. A photo has been submitted with your
request in lieu of a sample.
DPCI# 067-10-3183, described as a “Faux Rabbit Fur Throw,” is a 50 x 60-inch two-ply blanket. The face
side of the blanket is made of 100 percent polyester warp knit long pile faux rabbit fur fabric and the back
side is made of 100 percent polyester warp knit micro mink fabric. The sides are finished with a knife edge
and a second row of stitching approximately 1-inch from each edge forms a border or picture frame effect.
You state that the item is intended to provide warmth to an individual. The item is marketed under the
THRESHOLD™ brand and sold at Target stores.
The manufacturing operations for the faux rabbit fur throw 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 exported to Vietnam.
Vietnam:
Polyester micro mink fabric is knit and dyed.
Polyester woven labels and UPC paper labels are formed.
Polyester fabrics are cut and assembled by sewing into throws with a sewn-in labels.
The finished throw blankets 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withdrawn from warehouse, for consumption on or after July 1, 1996.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
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.
The blanket is classified under heading 6301, Harmonized Tariff Schedule of the United States (HTSUS). As
the blanket is made of two fabrics and the fabric-making process does not occur in a single country, territory
or insular possession, 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 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 subject merchandise is not knit to shape and heading 6301, HTSUS, is excepted under subparagraph
(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 merchandise, the most important manufacturing process occurs at the time of fabric
making. The fabrics for the instant item are sourced in more than one country. As no one fabric is more
important than the other, 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 blanket, the country of origin is conferred by the last country in which
an important assembly or manufacturing process occurred, that is, Vietnam.
HOLDING:
The country of origin of the “Faux Rabbit Fur Throw,” DPCI# 067-10-3183, is Vietnam 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 P. Forkan
Director
National Commodity Specialist Division