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

N356931 December 18, 2025 OT:RR:NC:N2:349 CATEGORY: Origin Ms. Nicole Robertson Berkshire Blanket 446 Main Street Ste# 1301 Worcester, MA 01608 RE: Country of origin determination for blankets; 19 CFR 102.21(c)(2); tariff shift Dear Ms. Robertson: This is in reply to your letter dated December 11, 2025, requesting a country of origin determination for two blankets, which will be imported into the United States. FACTS: Style 22430 is a 100 percent polyester, single layer, plush knit blanket measuring 50 × 60 inches. The plush fabric is printed with an all over print consisting of snow-covered pine trees and reindeer on a blue background with snowflakes. The edges are hemmed. Style 21592 is a 100 percent polyester, double layered, blanket measuring 50 × 60 inches. The face of the blanket consists of 100 percent polyester plush knit, printed, fabric. The all over print depicts snow covered pine trees with a green background. The backing fabric is 100 percent polyester knit faux shearling. The two layers are sewn together with a knife edge and 4-inch box stitch. The manufacturing operations for the Style 22430 and Style 21592 are as follows: VIETNAM: Plush fabric is formed by knitting. Faux shearling fabric is formed by knitting. (Style 21592) Plush fabric is exported to China on rolls. CHINA: Thread is formed. Plush fabric is printed. Plush fabric is cut and hemmed on all four sides. (Style 22430) Plush and faux shearling fabrics are cut and assembled by sewing. (Style 21592) Completed 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customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996.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 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.” The blankets are classified under heading 6301, Harmonized Tariff Schedule of the United States (HTSUS). As the fabric for each blanket is formed by the fabric-making process in a single country, that is, Vietnam, as per the terms of the tariff shift requirement, country of origin is conferred in Vietnam. HOLDING: The country of origin of the blankets, Style 22430 and Style 21592, is Vietnam in accordance with 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division