OT:RR:NC:N4:441
Kristy Perez-Naranjo
D&B Customs Brokers, LLC
8751 NW 11th Street
Pembroke Pines, FL 33024
RE: Classification and Country of Origin Determination for a Backpack; Substantial Transformation
Dear Ms. Perez-Naranjo:
This is in reply to your letter dated July 23, 2026, on behalf of your client ZSA Technology Labs, requesting
a classification and country of origin determination for a backpack, which will be imported into the United
States.
FACTS:
The subject merchandise is a backpack constructed of textile material with an outer surface of plastic
sheeting. The article is designed to provide storage, protection, organization, and portability to personal
effects during travel. The back of the pack has two straps that allow the user to wear it over the shoulders on
the back.
The manufacturing operations for the backpack are as follows:
United States
The fabric is manufactured
Indonesia
Receipt and inspection of all raw materials and components
Pattern preparation and material cutting (including the fabric panels, lining, reinforcement, and accessory
materials)
Sewing and assembly operations
Installation of zippers, webbing, straps, hardware, and accessories;
Construction of compartments
Quality control, labeling, final assembly, finishing and packaging for export.
ISSUE:
What are the classification and country of origin of the subject merchandise?
CLASSIFICATION:
The applicable subheading for the backpack will be 4202.92.4500, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for travel, sports, and similar bags, with outer surface of sheeting of plastic
or of textile material, other. The general rate of duty will be 20 percent ad valorem.
The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience
and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided
at https://hts.usitc.gov/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
COUNTRY OF ORIGIN:
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
The fabric emerges with a new name, character and use as a result of the cutting, sewing, and other processes
performed Indonesia. As such, the country of origin of the subject backpack is Indonesia.
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 Vikki Lazaro at
[email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division