Country of origin determination for feather and down accent pillow inserts; 19 CFR 102.21(c)(2); tariff shift

N353242 September 29, 2025 OT:RR:NC:N2:349 CATEGORY: Origin Ms. Yaping Shan Hangzhou Joyce Household Textiles Co. Ltd. No.2675 Xinluo Road, Xintang Street, Xiaoshan District Hangzhou 311201 China RE: Country of origin determination for feather and down accent pillow inserts; 19 CFR 102.21(c)(2); tariff shift Dear Ms. Shan: This is in reply to your letter dated September 3, 2025, requesting a country of origin determination for feather and down accent pillow inserts which will be imported into the United States. Photographs and product specifications pertaining to the items were submitted in lieu of a sample. FACTS: The subject merchandise is identified as a “Feather and Down Pillow Insert” to be imported in various shapes and sizes. The pillow inserts are made of an outer shell of 100 percent cotton woven fabric that is filled with 95 percent white duck feather and 5 percent white duck down. The shell fabric is bleached and dyed white. The fabric is not printed. With the exception of the body pillow, the pillow inserts contain self-fabric piping sewn along the edges. The body pillow insert has knife edges. The pillow inserts are packaged in a polyethylene (PE) bag and sold at retail in following types, SKU #s, sizes and Product #s: Item Description SKU # Finished Size Product # 1 Lumbar Pillow 11134A-12X21-WHITE 12 × 21 inches 25DFP02 2 Lumbar Pillow 11134A-14X30-WHITE 14 × 30 inches 25DFP03 3 Lumbar Pillow 11134A-14X40-WHITE 14 × 40 inches 25DFP04 4 Square Pillow 11134A-16-WHITE 16 × 16 inches 25DFP05 5 Square Pillow 11134A-18-WHITE 18 × 18 inches 25DFP06 6 Square Pillow 11134A-20-WHITE 20 × 20 inches 25DFP07 7 Square Pillow 11134A-22-WHITE 22 × 22 inches 25DFP08 8 Square Pillow 11134A-24-WHITE 24 × 24 inches 25DFP09 9 Euro Pillow 11134A-26-WHITE 26 × 26 inches 25DFP10 10 Large Boudoir Pillow 11134A-BLG-WHITE 16 × 24 inches 25DFP16 11 Medium Boudoir Pillow 11134A-BMED-WHITE 16 × 20 inches 25DFP17 12 Small Boudoir Pillow 11134A-BSML-WHITE 12 × 16 inches 25DFP12 13 Neck Pillow 11134A-BOL-WHITE 8 × 20 inches 25DFP11 14 Neck Pillow 11134A-NR-WHITE 6 × 15 inches 25DFP13 15 Body Pillow 11134A-MBP-WHITE 20 × 72 inches 25DFP01 16 Reading Wedge Pillow 11134A-RWL-WHITE 36 × 18 × 12 inches 25DFP14 17 Reading Wedge Pillow 11134A-RWM-WHITE 20 × 15 × 8 inches 25DFP15 The manufacturing operations for each feather and down pillow insert are as follows: Pakistan Cotton fabric is woven. Cotton fabric is shipped in rolls to China. China Cotton fabric is bleached, dyed white, and shrunk. Piping cord, self-fabric piping, labels, polyethylene (PE) bag and polyester sewing thread are produced. Duck feather and down are sourced. Fabric and piping are cut, sewn and assembled into an unfilled pillow shell. The pillow shell is filled with feathers and down and sewn closed with labels. The finished pillow inserts are packaged and exported to the 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:” 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 9404.90 Except for goods of subheading 9404.90 provided for in paragraph (e)(2) of this section, the country of origin of a good classifiable under subheading 9404.90 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 section 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. Based on the information provided in your letter, the pillow inserts are not included in the paragraph (e)(2) exception to the above tariff shift rule. Therefore, as the fabric comprising the pillow inserts is formed by the fabric-making process in a single country, that is Pakistan, country of origin is conferred in Pakistan. HOLDING: The country of origin for the pillow inserts is Pakistan 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, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division