The country of origin determination for a comforter and sheet storage container; 19 CFR 102.21(c)(2)

N353245 September 30, 2025 OT:RR:NC:N3:351 CATEGORY: Country of Origin Ms. Yaping Shan Hanghzhou Joyce Household Textiles Co.,Ltd. No.2675 Xinluo Road, Xintang Street, Xiaoshan District, Hangzhou 311201 China RE: The country of origin determination for a comforter and sheet storage container; 19 CFR 102.21(c)(2) Dear Ms. Shan: This is in response to your letter dated September 4, 2025, requesting a country of origin determination for two storage containers. Samples were provided to this office and will be retained for training purposes. The sample, described as a “Comforter Bag,” is a textile storage container intended to store and protect a comforter when not in use. The storage container is composed of 100 percent cotton woven canvas fabric laminated with thermoplastic polyurethane (TPU) film on the interior surface for waterproofing. The rectangular-shaped container is unlined and features a zipper closure on the top and extends halfway down one side; two self-fabric carrying handles sewn to the top and side for carrying; a clear plastic-sleeve pocket, measuring 2 ½ inches by 3 ½ inches, holds a blank paper card for labeling; and a “The Company Store” logo embroidered onto the front of the container. You state the storage container is available in three sizes and the SKU number is delineated by the size of the storage container: SKU# 11132G-S-NATURAL, small, measures 23 ½ inches wide x 19 ½ inches high x 6 ¾ inches gusset; SKU# 11132G-M-NATURAL, medium, measures 32” W x 19” H x 6” gusset; and SKU# 11132G-L-NATURAL, large, measures 30” W x 24” H x 10” gusset. The sample, described as a “Sheet Bag,” is a textile storage container intended to store and protect bed sheets when not in use. The storage container is composed of 100 percent cotton woven canvas fabric laminated with TPU film on the interior surface for waterproofing. The rectangular-shaped container is unlined and features a zipper closure on the top and extends down one side; has no carrying handles; a clear plastic-sleeve pocket, measuring 2 ½ inches by 3 ½ inches, holds a blank paper card for labeling; and a “The Company Store” logo embroidered onto the front of the container. You state the storage container is available in two sizes and the SKU number is delineated by the size of the storage container: SKU# 11133G-S-NATURAL, small, measures 12 inches wide by 9 inches high with 6 inches gusset, and SKU# 11133G-M-NATURAL, medium, measures 12” wide x 10” high x 7” gusset. You state the manufacturing operations for the comforter and sheet container are as follows: Pakistan: • 100 percent cotton canvas fabric is woven and shipped in rolls to China. China: • TPU film is produced. • Woven cotton canvas fabric is laminated with TPU film on one side. • Polyester sewing thread, embroidery thread, zipper, plastic-sleeve pocket and paper cards are produced. • Carrying handles for the comforter container are produced. • Fabric is cut to size and sewn. • Components are assembled and sewn onto the storage containers. • Logo is embroidered onto the front of each item. • The storage containers are packaged and shipped to the United States. ISSUE: What is the country of origin determination 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 bags are 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)(1) provides the rules used to determine the country of origin of a textile or apparel product under paragraph (c)(2) of this section. These rules are dependent on the classification of the good. The comforter and sheet container are classified under subheading 6307.90.9891, Harmonized Tariff Schedule of the United States (HTSUS). 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 6307.90 The country of origin of a good classifiable under subheading 6307.90 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 comforter and sheet container are comprised of woven fabric formed by a fabric-making process in a single country, that is Pakistan. Therefore, pursuant to 19 CFR 10.21(c)(2), the country of origin of the comforter and sheet container is Pakistan. HOLDING: The country of origin of the comforter and sheet container 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 Kristine Dodge at kristine.dodge@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division