Country of origin determination for a blanket; 19 CFR 102.21(c)(2); tariff shift

N348085 May 9, 2025 OT:RR:NC:N2:349 CATEGORY: Origin Mr. Yiqin Weng Maersk Logistics & Services China Limited 25 F, No.757, Meng Zi Road Shanghai 200023 China RE: Country of origin determination for a blanket; 19 CFR 102.21(c)(2); tariff shift Dear Mr. Weng: This is in reply to your letter dated April 22, 2025, submitted on behalf of your client, Shen Jun Trading Limited, requesting a country of origin determination for a fleece blanket which will be imported into the United States. A sample was not provided. FACTS: You state the subject merchandise, Model Number SH20250402, consists of a blanket made from a single layer of 100 percent polyester, dyed, jacquard woven, fleece fabric. During the weaving process, horizontal ribs are formed on the surface of the fleece fabric. The blanket has a double needle hemmed edge and measures 50 × 60 inches. The manufacturing operations for the blanket are as follows: Scenario 1 China Fleece fabric is woven and dyed. Fabric is exported to Pakistan. Pakistan Fabric is cut and sewn. Finished blanket is packed and exported to the United States. Scenario 2 China Fleece fabric is woven. Greige fabric is exported to Pakistan. Pakistan Fabric is dyed. Fabric is cut and sewn. Finished blanket is packed and exported to the United States. Scenario 3 China Polyester yarn is spun. Yarn is exported to Pakistan. Pakistan Fleece fabric is woven. Fabric is dyed. Fabric is cut and sewn. Finished blanket is packed 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customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996.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 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). Heading 6301, HTSUS, is not provided for under paragraph (e)(2) of section 102.21. Therefore, as the blanket is comprised of fabric formed in a single country, as per the terms of the tariff shift requirement, country of origin is conferred in China in scenarios 1 and 2 and Pakistan in scenario 3. HOLDING: The country of origin of the blanket, Model Number SH20250402, is China in scenarios 1 and 2 and Pakistan in scenario 3. 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 kimberly.a.wachtel@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division