Country of origin determination for plush blankets; 19 CFR 102.21(c)(2); tariff shift

N350479 July 15, 2025 OT:RR:NC:N2:349 CATEGORY: Origin Ms. Silvia Hall All Strong 950 Raco Drive, Suite F Lawrenceville, GA 30046 RE: Country of origin determination for plush blankets; 19 CFR 102.21(c)(2); tariff shift Dear Ms. Hall: This is in reply to your letter dated June 22, 2025, requesting a country of origin determination for plush blankets, which will be imported into the United States. Photographs were provided in lieu of the sample. FACTS: The subject merchandise, “Warm & Cozy Plush Velvet Blanket and Throw” and “4 in 1 Cozy and Practical Travel Throw,” are plush blankets made from a single layer of 100 percent polyester knit pile fabric. The fabric is dyed or printed. All four edges are hemmed. The “Warm & Cozy Plush Velvet Blanket” will be imported in the following sizes and colors: Twin 66” x 90”, Gray Plaid (Model #6BGP066090); Twin 66” x 90”, Solid Gray (Model #6BGR066090); Twin 66” x 90” Navy Blue (Model #6BNV066090); Twin 66” x 90”, Tan (Model #6BTN066090); Full/Queen 90” x 90”, Gray Plaid (Model #6BGP090090); Full/Queen 90” x 90”, Solid Gray (Model #6BGR090090); Full/Queen 90” x 90”, Navy Blue (Model #6BNV090090); Full/Queen 90” x 90”, Tan (Model #6BTN090090); King 102” x 90”, Gray Plaid (Model #6BGP102090); King 102” x 90”, Solid Gray (Model #6BGR102090); King 102” x 90”, Navy Blue (Model #6BNV102090); and King 102” x 90”, Tan (Model #6BTN102090). The “4 in 1 Cozy and Practical Travel Throw” measures 45” x 60” and will be imported in the following colors: Navy (Model #6ANV450600), Gray (Model #6AGR450600), Tan (Model #6ATN450600), and Dusty Pink (Model #6ACL450600). The items will be imported and marketed under Mainstays™ and sold at retail in Walmart stores and various online platforms. The manufacturing operations for the plush blankets are as follows: China Plush fabric is knitted. Plush fabric is exported to Vietnam. Vietnam Plush fabric is dyed or printed. Plush fabric is brushed, polished and treated with anti-pilling chemical. Plush fabric is cut to size and hemmed. Finished plush blankets are packaged 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 the fabric making process. The “fabric-making process” is defined in 19 CFR 102.21(b)(2) as “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 subject blankets are classified under heading 6301, Harmonized Tariff Schedule of the United States (HTSUS), and are, therefore, not subject to the paragraph (e)(2) exception. As the fabric for the plush blankets is 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 plush blankets is China pursuant to 19 CFR 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