U.S. Customs and Border Protection · CROSS Database
Country of origin determination for a coir mat; 19 CFR 102.21(c)(1); wholly obtained or produced in a single country
N359466 March 26, 2026 OT:RR:NC:N2:349 CATEGORY: Origin Ms. Nicol Tsang Albert & Hazel LLC 325 Cafferty Road Pipersville, PA 18947 RE: Country of origin determination for a coir mat; 19 CFR 102.21(c)(1); wholly obtained or produced in a single country Dear Ms. Tsang: This is in reply to your letter dated March 5, 2026, requesting a country of origin determination for a coir mat, which will be imported into the United States. In lieu of a sample, photographs were submitted along with your request. The subject merchandise, item# 264596, described as a “(H)Halloween Icons Doormat,” is a mat made from coir (coconut) yarns. The coir tufts have been cut and set vertically into a vinyl base. The mat is not woven, tufted or knit. The rectangular mat measures 24 x 16 inches and features a printed Halloween motif that includes jack-o-lanterns, ghosts, candy corn and spiderwebs. The coir mat is imported for retail sale and marketed under the Festive Voice™ brand by Walgreen stores. The manufacturing operations for the coir mat are as follows: India Coconut is grown and harvested. PVC resin compound is formed and paint is manufactured. Coir fibers are spun into yarns and spooled. Coir yarn spools are loaded into a creel stand and fed into the embedding machine. Coir yarns are cut to pile height, embedded and pressed into a liquid PVC backing. The coir mat passes through heated and cooled conveyor belts, sheared and trimmed to size. The top layer of the coir mat is printed with a Halloween motif design. A paper tag is secured to the finished coir mats, packaged and shipped 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customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996.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 coir mat was wholly obtained or produced in a single country, that is, India, the country of origin is conferred in India. HOLDING: The country of origin of the coir mat is India pursuant to 19 CFR 102.21(c)(1). 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division