Country of origin determination for duvet cover set; 19 CFR 102.21(c)(2); tariff shift

N348571 May 29, 2025 OT:RR:NC:N2:349 CATEGORY: Origin Richard Writsman Continental Agency Inc. 1768 W Second Street Pomona, CA 91766 RE: Country of origin determination for duvet cover set; 19 CFR 102.21(c)(2); tariff shift Dear Mr. Writsman: This is in reply to your letter dated May 2, 2025, requesting a country of origin determination for a duvet cover set, which will be imported into the United States, on behalf of Shen Jun Trading Limited. A sample was provided and will be disposed of. FACTS: The subject merchandise consists of a duvet cover and sham(s). The duvet cover and sham(s) are each constructed with a front panel of 100 percent cotton jacquard woven waffle fabric and back panel(s) of 100 percent cotton plain woven fabric. The duvet cover has a knife edge and an opening at the bottom end with a button closure. The front of the sham includes a 1 ¼ inch border of the plain woven back fabric around each side creating a picture frame effect and has a knife edge. The back of the sham is constructed of two panels that slightly overlap at the center. The set will be imported in standard bed sizes in a 100 percent cotton plain woven textile bag with handles and a button closure. The twin set will include a duvet cover and a pillow sham. The full, queen, king, California king, oversized queen and oversized king sizes will include a duvet cover and two pillow shams. The sets will be imported in assorted colors: white, navy blue, malachite green, and brick dust pink. The manufacturing operations for the duvet cover and sham(s) are as follows: China All fabrics are woven and dyed. All fabrics are exported to Pakistan. Pakistan Fabrics are cut and assembled by sewing into duvet covers and shams. Finished duvet covers and shams are inspected, ironed and packaged for export 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customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996.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. Subject to paragraph (d) of this section, 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). At the outset, we consider the Duvet Cover Set “Cotton-Waffle-Solid Style” to be a set under the General Rules of Interpretation (GRI). Section 102.21(d) addresses the treatment of sets for country of origin purposes. Section 102.21(d) provides the following: Where a good classifiable in the HTSUS as a set includes one or more components that are textile or apparel products and a single country of origin for all of the components of the set cannot be determined under paragraph (c) of this section, the country of origin of each component of the set that is a textile or apparel product shall be determined separately under paragraph (c) of this section. Thus, per the terms of Section 102.21(d), the country of origin of each item in the set must be determined separately if there is not a single country of origin for the entire set. 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. As the fabrics for the duvet cover and sham(s) are formed in a single country, that is, China, as per the terms of the tariff shift requirement, country of origin is conferred in China. HOLDING: Pursuant to 19 CFR 102.21(c)(2), the country of origin of the duvet cover and sham(s) is China. 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