Country of origin determination for a decorative pillow; 19 CFR 102.21(c)(2); tariff shift

N356883 December 18, 2025 OT:RR:NC:N2:349 CATEGORY: Origin Ms. Gloria Yan Shanghai Sunwin Industry Group Co.,Ltd. No.17, Lane 688, Hengnan Road, Minhang District Shanghai 201112 China RE: Country of origin determination for a decorative pillow; 19 CFR 102.21(c)(2); tariff shift Dear Ms. Yan: This is in reply to your letter dated December 10, 2025, requesting a country of origin determination for a decorative pillow, which will be imported into the United States. Photographs of the pillow were submitted in lieu of a sample. FACTS: The subject merchandise, described as the “Christmas Wreath Themed Toss Pillow,” Style Number 26C6SWTP02, is a decorative pillow measuring 18 × 18 inches. The front of the pillow is comprised of 100 percent polyester woven slub fabric, with a printed wreath design and embroidered holly leaves, red berries and a red bow at the top. The back fabric is comprised of printed 100 percent polyester velvet. The printing is an all over print of pine needles, holly leaves and berries. The pillow shell includes 100 percent polyester velvet piping on the front of the pillow along the inside of the flanged edges. The pillow is stuffed with polyester staple fiber. The manufacturing operations for the decorative pillow, Style Number 26C6SWTP02, are as follows: CHINA: Polyester slub fabric (front of pillow) is woven. Polyester velvet fabric (back of pillow and piping) is woven. Fabrics are exported to Vietnam. VIETNAM: Polyester staple fiber filling is manufactured. Labels and sewing thread are formed. Front and back fabrics are printed; front is embroidered. Front and back fabrics are cut to size and shape. Panels are sewn into pillow shell and assembled with labels and piping. Pillow shell is filled with polyester staple fiber and sewn closed. Finished pillow is 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customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996.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 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 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.” Paragraph (e)(2) in pertinent part states, For goods of HTSUS headings 6213 and 6214 and HTSUS subheadings 6117.10, 6302.22, 6302.29, 6302.52, 6302.53, 6302.59, 6302.92, 6302.93, 6302.99, 6303.92, 6303.99, 6304.19, 6304.93, 6304.99, 9404.90.85 and 9404.90.95, except for goods classified under those headings or subheadings as of cotton or of wool or consisting of fiber blends containing 16 percent or more by weight of cotton: (i) The country of origin of the good is the country, territory, or insular possession in which the fabric comprising the good was both dyed and printed when accompanied by two or more of the following finishing operations: bleaching, shrinking, fulling, napping, decating, permanent stiffening, weighting, permanent embossing, or moireing; (ii) If the country of origin cannot be determined under paragraph (e)(2)(i) of this section...the country of origin is the country, territory, or insular possession in which the fabric comprising the good was formed by a fabric-making process; The pillows are classifiable in subheading 9404.90.20, Harmonized Tariff Schedule of the United States (HTSUS), and are not subject to paragraph (e)(2). All of the fabric comprising the pillow is formed in China. As the fabric-making process occurs 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 “Christmas Wreath Themed Toss Pillow,” Style Number 26C6SWTP02, is China. 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