Country of origin determination for cleaning mop pads; 19 CFR 102.21(c)(2); tariff shift

N350428 July 14, 2025 OT:RR:NC:N2:349 CATEGORY: Origin Ms. Selina Xu Aquastar Inc. DBA Concept Manufacturing 13417 Benson Ave. Chino, CA 91710 RE: Country of origin determination for cleaning mop pads; 19 CFR 102.21(c)(2); tariff shift Dear Ms. Xu: This is in reply to your letter dated June 20, 2025, requesting a classification and country of origin determination for mop pads, which will be imported into the United States. Photographs were provided in lieu of the sample. FACTS: The subject merchandise, item# 31704, described as “Cleaning Pad GRS Bulk,” consists of a 280-piece pack of reusable microfiber cleaning mop pads used for dry dusting and mopping on various floor surfaces. The cleaning mop pad consists of three layers of warp knit pile fabric assembled together with two rows of straight stitches sewn, lengthwise, across the middle of pad and overlock stitching around the edges. The edges are finished with nonwoven binding. The face fabric is composed of 94 percent polyester and 6 percent polyamide microfiber warp knit pile fabric and is the cleaning side of the mop to trap dirt, dust and debris, and absorb water. The middle fabric is composed of 100 percent polyester warp knit pile fabric to improve water absorption. The top fabric, when in use, is composed of 100 percent polyester brushed warp knit pile fabric. This fabric forms the backing of the cleaning mop pad and facilitates the attachment of the mop pad to the mop’s frame. The rectangular shaped mop pad measures approximately 18¼ inches in length by 5 inches in width. You state the mop pads are typically used with the Bona® family of mops. The pads are sold in bulk to Bona Kemi USA Inc. The manufacturing operations for the “Cleaning Pad GRS Bulk,” item# 31704, are as follows: China Microfiber knit pile (face) fabric is formed. Polyester warp knit pile (middle) fabric is formed. Polyester brushed warp knit pile (backing) fabric is formed. Nonwoven binding fabric, labels and thread are formed. All fabrics, labels and thread are shipped to Vietnam. Vietnam Fabrics forming the face, middle and backing are slit and cut to the specified size. The three fabric layers are sewn together. The label is sewn to mop pad. Nonwoven binding is sewn around the edges. Finished product is inspected, packaged and shipped to 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:” The mop pads are classified under subheading 6307.10, Harmonized Tariff Schedule of the United States (HTSUS). Paragraph (e)(1), 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 6307.10 The country of origin of a good classifiable under subheading 6307.10 is the country, territory, or insular possession in which the fabric comprising the good is 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. As all of the fabrics for the microfiber cleaning mop pad are formed by the fabric making process 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 “Cleaning Pad GRS Bulk”, item# 31704, is China pursuant 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 kimberly.a.wachtel@cbp.dhs.gov. Sincerely, James Forkan Acting Director National Commodity Specialist Division