Country of origin determination for duvet covers, pillow shams and quilts; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.21(c)(4); most important assembly or manufacturing process

N359713 April 2, 2026 OT:RR:NC:N2:349 CATEGORY: Origin Matthew Bock Bock Trade Law 53 State Street, Suite 500 Boston, MA 02109 RE: Country of origin determination for duvet covers, pillow shams and quilts; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.21(c)(4); most important assembly or manufacturing process Dear Mr. Bock: This is in reply to your letter dated March 13, 2026, requesting a country of origin determination on behalf of your client, Sarita Handa Exports PVT. Ltd., for duvet cover sets and quilts, which will be imported into the United States. In lieu of samples, photographs were submitted with your request. FACTS: The subject merchandise consists of three duvet cover sets, consisting of a duvet cover and two shams, and two quilts. The Moonstone Duvet Cover Set consists of a duvet cover and two pillow shams. The front of the duvet cover and front and back of the pillow shams are composed of 69 percent polyester and 31 percent cotton jacquard woven fabric that has a textured marble appearance. The back of the duvet cover is composed of 60 percent cotton and 40 percent polyester woven fabric. The duvet cover and the pillow shams feature a knife edge finish and a zipper closure one inch from the bottom seam on the back to securely encase the duvet insert and the pillow. The duvet cover also includes self-fabric internal ties placed at each corner to secure the duvet in place. The duvet cover will be imported in sizes Full/Queen with standard sized pillow shams, measuring 20 × 28 inches, and King with 20 × 36-inch pillow shams. The set is imported by Macy’s Department Stores as part of their Hotel Luxury Bedding Collection. The Textured Chevron Duvet Cover Set consists of a duvet cover and two pillow shams. The front of the duvet cover and the front and back of the pillow shams are composed of 60 percent polyester and 40 percent cotton yarn-dyed jacquard woven fabric that forms an indistinct chevron pattern. The back of the duvet cover is composed of 100 percent cotton woven fabric. The duvet cover and pillow shams feature a self-flange with a knife edge finish and a zipper closure one inch from the bottom seam on the back to securely encase the duvet insert and the pillow. The duvet cover also includes 7 ½ inch long and 3/8-inch-wide self-fabric internal ties at each corner to secure the duvet in place. The duvet cover will be imported in sizes Full/Queen with standard pillow shams, measuring 20 × 28 inches, and King with 20 × 36-inch pillow shams. The set is imported by Macy’s Department Stores as part of their Hotel Luxury Bedding Collection. The Broken Stripe Duvet Cover Set consists of a duvet cover and two pillow shams. The front of the duvet cover and the front and back of the pillow shams are composed of 100 percent polyester yarn-dyed jacquard woven fabric that forms an indistinct stripe pattern of various widths. The back of the duvet cover is composed of 100 percent cotton woven fabric. The duvet cover and pillow shams feature a self-flange edge finish and a zipper closure 1 inch from the bottom seam of the back to securely encase the duvet insert and the pillow. The duvet cover also includes 7 ½ inch long and 3/8-inch-wide self-fabric internal ties at each corner to secure the duvet in place. The duvet cover will be imported in sizes Full/Queen with standard pillow shams measuring 20 × 28, and King with 20 × 36-inch pillow shams. The set is imported by Macy’s Department Stores as part of their Hotel Luxury Bedding Collection. The Velvet Lattice Quilt is a bed covering with a shell of 100 percent cotton fabric. The face of the shell is 100 percent cotton velvet woven fabric and the back fabric is 100 percent cotton sheeting. The quilt is stuffed with 100 percent polyester batting. A cross stitch pattern is stitched through the three layers forming a lattice pattern. The edges are finished with a double slub one inch width flange with a frayed edge or a knife edge finish. The quilt is imported in Twin, Full/Queen and King sizes. The quilt is imported by Pottery Barn. The Heirloom Scalloped Quilt is a bed covering with a shell of 100 percent cotton sheeting and 100 percent cotton batting filling. The quilt features a diamond quilting pattern in the center with a multi picture frame effect. The innermost frame is formed by three parallel rectilinear lines of quilting followed by a curvilinear intertwined pattern, a larger rectilinear frame consisting of seven parallel rectilinear lines of quilting and a larger curvilinear intertwined pattern. The edges are scalloped and finished with binding. The quilt is imported in Twin, Full/Queen and King sizes. The quilt is imported by Pottery Barn. The manufacturing operations for the duvet covers, shams and quilts are as follows: Bangladesh Polyester and cotton fibers are spun into yarns. All outer facing/shell fabrics, binding fabric and double slub fabric are woven. All griege woven fabric are exported to India. India Sewing thread, zippers, cotton nonwoven batting and polyester nonwoven batting are formed. Fabrics are subject to cleaning, bleaching, dyeing, rinsing, drying, heat steaming, shaping, pre-shrinking and final inspection. Fabrics are cut and assembled by sewing into duvet covers, pillows shams, and quilts. Quilts are quilted. Finished items are inspected, packaged, labeled 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 (d) states, “Where a good classifiable in the Harmonized Tariff Schedule of the United States (HTSUS) as a set includes one or more components that are textile or apparel products and a single country of origin for all of the components of the set cannot be determined under paragraph (c) of this section, the country of origin of each component of the set that is a textile or apparel product shall be determined separately under paragraph (c) of this section.” We consider the “Moonstone Duvet Cover Set,” the “Textured Chevron Duvet Cover Set,” and the “Broken Stripe Duvet Cover Set” to be sets under the General Rules of Interpretation (GRI). 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. Proceeding to 19 CFR 102.21(c)(2), we note that the subject quilts are classified in subheading 9404.40, Harmonized Tariff Schedule of the United States (HTSUS). There is no current rule to determine the country of origin of a textile article classified under subheading 9404.40, HTSUS. Prior to 2022, the corresponding HTSUS classifications for subheading 9404.40, HTSUS, were subheadings 9404.90.80 and 9404.90.85, HTSUS. Paragraph (e)(2) of Section 102.21 has not been updated with the current tariff subheadings. Therefore, we follow the rule corresponding to the prior classifications. 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) 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. 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 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. Paragraph (e)(2) states, in pertinent part, For goods of HTSUS headings 6213 and 6214 and HTSUS subheadings 6117.10, 6302.22, 6302.29, 6302.53, 6302.59, 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, except for goods of HTSUS subheading 6117.10 that are knit to shape or consist of two or more component parts, 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; Based on the information provided, the duvet covers are classified under subheading 6302.32, HTSUS. The pillow shams are classified under subheading 6304.93. The quilts are classified under subheading 9404.40, HTSUS. The duvet covers and quilts are not covered by paragraph (e)(2); therefore, we apply the tariff shift rule under paragraph (e)(1). As the fabric comprising the duvet covers is formed by the fabric-making process in a single country, that is, Bangladesh, as per the terms of the tariff shift requirement, country of origin is conferred in Bangladesh. With respect to the quilts, the fabric is not formed in a single country. The quilt’s shell is formed in Bangladesh and the nonwoven batting is formed in India; therefore, we proceed to paragraph (c)(3) for these items. With respect to the pillow shams classified under subheading 6304.93, HTSUS, paragraph (e)(2) applies. As the fabric is not both dyed and printed, subparagraph (i) is inapplicable and we apply subparagraph (ii). As the fabric forming the pillow shams is formed in a single country, that is, Bangladesh, as per the terms of the tariff shift requirement, country of origin is conferred in Bangladesh. Paragraph (c)(3) states, “Where the country of origin of a textile or apparel product cannot be determined under paragraph (c) (1) or (2) of this section: if the good was knit to shape, the country of origin of the good is the single country, territory, or insular possession in which the good was knit; or except for fabrics of chapter 59 and goods of headings 5609, 5807, 5811, 6213, 6214, 6301 through 6306, and 6308, and subheadings 6307.10, 6307.90, 9404.90, and 9619.00.31-33 if the good was not knit to shape and the good was wholly assembled in a single country, territory, or insular possession, the country of origin of the good is the country, territory, or insular possession in which the good was wholly assembled.” As the quilts are not knit to shape and are excepted from subparagraph (c)(3)(ii), Section 102.21 (c)(3) is inapplicable. Paragraph (c)(4) states, “Where the country of origin of a textile or apparel product cannot be determined under paragraph (c) (1), (2) or (3) of this section, the country of origin of the good is the single country, territory, or insular possession in which the most important assembly or manufacturing process occurred.” The most important assembly or manufacturing process occurs at the time of the formation of the outer shell fabric. It is the outer shell fabric which in essence, identifies the merchandise, and thus creates its salability. Accordingly, the country of origin of the subject quilts is the single country in which the outer shell fabric is formed, that is, Bangladesh. HOLDING: The country of origin of the duvet covers is Bangladesh in accordance with 19 CFR 102.21 (c)(2) and 19 CFR 102.21 (e)(1). The country of origin of the pillow shams is Bangladesh in accordance with 19 CFR 102.21 (c)(2) and 19 CFR 102.21 (e)(2)(ii). The country of origin of the quilts is Bangladesh in accordance with 19 CFR 102.21 (c)(4). 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