Country of origin and marking determination for tea towels; 19 CFR 102.21(c)(2); tariff shift

N354457 October 24, 2025 OT:RR:NC:N2:349 CATEGORY: Origin; Marking Mr. William Yeh Design International Group, Inc. 755 Epperson Dr. City of Industry, CA 91748 RE: Country of origin and marking determination for tea towels; 19 CFR 102.21(c)(2); tariff shift Dear Mr. Yeh: This is in reply to your letter dated October 1, 2025, requesting a country of origin and marking determination for tea towels, which will be imported into the United States. In lieu of a sample, photographs were submitted with your request. FACTS: The subject merchandise, item #721345, is described as a 2-Piece Tea Towel Set, intended to be used for household cleaning and serving. The towels are made from 100 percent cotton, printed, plain woven fabric. All of the edges are hemmed. There is a 100 percent cotton woven fabric hanging loop sewn on the back along the top hem. The tea towels in the set will each be of a different printed pattern design. Both tea towels measure 15.5 x 25 inches. The 2-Piece Tea Towel Set is imported for retail sale and marketed under the Festive Voice™ brand by Walgreen stores. The manufacturing operations for the tea towels are as follows: India: Yarn is formed. Cotton woven hanging loop is formed. Toweling fabric is woven, bleached, and printed. Toweling fabric is cut and hemmed to make a finished rectangular tea towel. Woven hanging loop is attached by sewing. Finished tea towels are packaged on a plastic hanger and shipped to United States. ISSUE: What is the country of origin of the subject merchandise for marking purposes? 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customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996.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 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. Based on the information provided in your letter, the tea towels are classified under subheading 6302.91, HTSUS, which is not included in the paragraph (e)(2) exception to the above tariff shift rule. Therefore, as the fabric comprising the tea towels is formed in a single country, that is, India, country of origin is conferred in India. MARKING: The marking statute, Section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. As provided in Section 134.41(b), Customs Regulations (19 C.F.R. 134.41(b)), the country of origin marking is considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it without strain. With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 C.F.R. 134.41(a)), provides that as a general rule marking requirements are best met by marking worked into the article at the time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk, molded in, or etched. However, Section 134.44, Customs Regulations (19 C.F.R. 134.44), generally provides that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate purchaser unless deliberately removed is acceptable. The proposed marking, “MADE IN INDIA,” placed on both the front and back of the hang tag secured to the front of the 2-Piece Tea Towel Set with a T-tag retail fastener punched through the fabric and a plastic hanger, satisfies the marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134 and is an acceptable country of origin marking. Additionally, please note that separate Federal Trade Commission marking requirements exist regarding country of origin, fiber content, and other information that must appear on many textile items. You should contact the Federal Trade Commission, Division of Enforcement, 600 Pennsylvania Avenue, N.W., Washington, D.C., 20580, for information on the applicability of these requirements to this item. Information can also be found at the FTC website, www.ftc.gov. HOLDING: The country of origin of the 2-Piece Tea Towel Set, Item # 721345, is India pursuant to 19 CFR 102.21(c)(2). The proposed marking, “MADE IN INDIA,” attached to the set satisfies the marking requirements under 19 U.S.C. 1304 and 19 CFR Part 134. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division