The tariff classification and country of origin determination for a sun shelter; 19 CFR 102.21(c)(5)

N360050 April 21, 2026 OT:RR:NC:N3:351 CATEGORY: Classification, Origin TARIFF NO.: 6306.22.9030 Mr. Adam Klaser C.H. Robinson Worldwide, Inc. 26555 Evergreen Road Southfield, MI 48076 RE: The tariff classification and country of origin determination for a sun shelter; 19 CFR 102.21(c)(5) Dear Mr. Klaser: This is in reply to your letter dated March 25, 2026, requesting a classification and country of origin determination for a sun shelter on behalf of your client, Westfield Outdoors. Samples of fabric swatches used to produce the item and photographs of the sun shelter were provided with your request. Item #HW-20006, described as a “Sun shelter,” is a 3-person portable pop-up tent designed to provide temporary shelter at the beach. The open half-bell-shaped tent consists of a roof, three walls, and a floor with a pop-up frame composed of fiberglass. The walls and roof are constructed of 100 percent polyester woven dyed fabric coated with polyurethane on one side and finished with a waterproof surface. The non-detachable, hexagon-shaped floor is constructed of 100 percent polyethylene strips laminated on both sides. The floor measures 91 inches in length and 75 inches at its widest point. The floor extends past the opening of the shelter and tapers to a width of 40 ½ inches. The shelter features a window on each wall composed of 100 percent polyester knit mesh fabric for ventilation and includes four steel stakes and four fillable sandbags to weigh down the shelter at each corner. Each sandbag measures 12 ½ inches by 8 ½ inches and features a drawstring closure. The shelter measures 9 feet in length by 6 feet in width by 60 inches in height when it is fully assembled. The tent has a net weight of 7 pounds, a floor area of 56 ½ square feet, and a standing height of 54 inches. The shelter is imported with a carrying case that houses the shelter, stakes, and sandbags. The zippered carrying case measures 36 inches in length by 6 ¼ inches in width by 6 ¼ inches in height and features two webbed carrying straps. Both the carrying case and sandbags are composed of the same material as the roof and walls. The stake bag is composed of the same material as the floor. The manufacturing operations for the sun shelter are as follows: China: • 100 percent polyester fabric for the walls, roof, carrying case, sandbag, and stake bag ribbon is woven, dyed, coated on one side with polyurethane waterproof surface and shipped in rolls to Cambodia. • 100 percent polyester mesh fabric for windows is knitted, dyed, and shipped in rolls to Cambodia. • The thread, polypropylene braided drawstring, zippers, zipper tape, webbing straps, fiberglass poles, steel stakes, plastic foot petals, and plastic parts are produced and shipped to Cambodia. South Korea: • 100 percent polyethylene strip fabric for the floor and stake bag is woven, laminated on both sides, and shipped in rolls to Cambodia. Cambodia: • Fabric is cut into shape and size. • Fabric is sewn and hemmed to create a sun shelter, a carrying bag, four sandbags, and a stake bag. • Sixteen fiberglass poles are pre-connected by plastic parts and inserted into the shelter to create a pop-up tent. • The steel stakes are placed into the stake bag. • The sun shelter, stake bag, and sandbags are placed in the carrying bag. • The carrying bag is packaged in a carton and shipped to the United States. ISSUE: What are the classification and country of origin of the subject merchandise? CLASSIFICATION: You have suggested that the sun shelter should be classified under subheading 6306.22.9030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tarpaulins, awnings and sunblinds; tents (including temporary canopies and similar articles); sails for boats, sailboards or landcraft; camping goods: Tents (including temporary canopies and similar articles): Of synthetic fibers: Other: Other.” We agree. The general rate of duty will be 8.8 percent ad valorem. The classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Since no one heading in the tariff schedule covers the sun shelter, carrying case, stake bags, and sandbags in combination, GRI 1 cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character. In determining the essential character various factors may be used to determine the component which imparts the essential character to the composite article. The sun shelter is the primary component that provides protection from the sun when used at the beach. The carrying case is specially designed to hold, store, and transport the sun shelter, sandbags, and stake bag. The sandbag is designed to hold sand to weigh down the sun shelter. The stake bag is designed to hold, store, and transport the stakes. Therefore, in accordance with GRI 3(b), it is the opinion of this office that the sun shelter imparts the essential character and thus determines the classification. Accordingly, the carrying case, sandbags, and stake bag are classified with the subject sun shelter under subheading 6306.22.9030, HTSUS. 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 fabrics are manufactured in China and South Korea. The fabric for the roof, walls, and windows is manufactured in China. The fabric for the floor is woven and laminated in South Korea. As the fabric comprising the sun shelter did not occur in a single country, Section 102.21(c)(2) is not applicable. Section 102.21(c)(3) states that, "Where the country of origin of a textile or apparel product cannot be determined under paragraph (c)(1) or (2) of this section": (i) 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 (ii) Except for goods of heading 5609, 5807, 5811, 6213, 6214, 6301 through 6306, and 6308, and subheadings 6209.20.5040, 6307.10, 6307.90, and 9404.90, 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 sun shelter was not knit to shape, and heading 6306 is excepted from provision (ii), Section 102.21 (c)(3) is inapplicable. Section 102.21 (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 manufacturing process occurs at the time of fabric making. As the fabrics for the sun shelter are formed in more than one country, and no one fabric is more important than the other, country of origin cannot be readily determined based on the fabric making process. As such, paragraph (c)(4) is not applicable. Paragraph (c)(5) states, “Where the country of origin of a textile or apparel product cannot be determined under paragraph (c) (1), (2), (3) or (4) of this section, the country of origin of the good is the last country, territory, or insular possession in which an important assembly or manufacturing process occurred.” Accordingly, the country of origin is conferred by the last country in which an important assembly occurred, that is, Cambodia, where the components were cut, sewn, assembled, finished, and packed. HOLDING: The applicable subheading for the sun shelter will be 6306.22.9030, HTSUS, and the country of origin is Cambodia pursuant to 19 CFR 102.21(c)(5). The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Kristine Dodge at kristine.dodge@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division