Country of origin determination for a sheet set and comforter; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.21(c)(4); most important assembly or manufacturing process; 19 CFR 102.13; De Minimis

N360170 April 22, 2026 OT:RR:NC:N2:349 CATEGORY: Origin Mr. Tyler Keith Flexport Customs, LLC 100 California Street, Floor 5 San Francisco, CA 94111 RE: Country of origin determination for a sheet set and comforter; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.21(c)(4); most important assembly or manufacturing process; 19 CFR 102.13; De Minimis Dear Mr. Keith: This is in reply to your letter dated March 30, 2026, requesting a country of origin determination on behalf of your client, Rest, Inc., for a sheet set and comforter which will be imported into the United States. Representative samples, fabric swatches, photographs, and schematic diagrams, were provided and will be retained by this office for training purposes. The subject merchandise, SKU# REST-ISS01F, is a four-piece sheet set consisting of a fitted sheet, a flat sheet and two pillowcases. All items in the set are of dyed knitted fabric composed of 87 percent polyamide and 13 percent elastane. The fabric is neither printed nor napped. The fitted sheet features a 2.5-centimeter-wide elasticized woven band sewn along the edges. The flat sheet has a 20-centimeter hem along the top edge, and a 1.5-centimeter rolled hem on three sides. The pillowcases have an envelope closure with a 20-centimeter hem. The fitted sheet, flat sheet and two pillowcases do not contain any embroidery, lace, braid, edging, trimming, piping, or applique. The sheet set is imported for retail sale and marketed under the Rest® brand as a temperature-regulating sheet set. The sheet sets are available in the following sizes listed below: Cooling Sheet Set (4pcs) Fitted Sheet Flat Sheet Pillowcases Full 51 × 71 × 15 inches 93 × 108 inches 29 × 19 inches Queen 56 × 76 × 15 inches 93 × 108 inches 29 × 29 inches King 72 × 76 × 15 inches 104 × 108 inches 35 × 19 inches California King 68 × 80 × 15 inches 104 × 108 inches 35 × 19 inches The subject merchandise, SKU# REST-SCD00T-N, is a reversible quilted comforter made with an outer shell of 90 percent polyamide and 10 percent elastane knitted fabric. The face and back panel fabric is dyed a solid color. The comforter is filled with a nonwoven batting of 30 percent lyocell and 70 percent triexta. The three layers may be quilted together in a variety of patterns including box, diamond, channel, and wave patterns. Per your submission, the comforter contains no embroidery, lace, braid, edging, trimming, or applique work, but it does feature 100 percent polyester piping sewn on the four sides of the comforter between the front and back panels. This reversible quilted comforter is imported in the following sizes: Twin/Twin XL (68” x 90”), Full/Queen (90” x 90”), and King/California King (106” x 90”). You state that the reversible quilted comforter is imported in retail packaging and marketed under Rest® brand as a temperature-regulating article of bedding. The manufacturing operations for the sheet set are as follows: China: Polyamide (nylon) and elastane yarn is formed. Yarn is exported to South Korea. South Korea: Polyamide (nylon) and elastane griege knitted fabric is formed. Polyamide (nylon) and elastane griege knitted fabric is exported to China. China: Narrow woven elasticized fabric (fitted sheet) and sewing thread are formed. Griege knitted fabric formed in South Korea is shaped, dyed, washed, inspected. Finished fabric is cut and assembled by sewing into a fitted sheet, a flat sheet and pillowcases. Finished fitted sheet, flat sheet and pillowcases are labeled, bagged, sealed, and boxed for shipment to the United States. The manufacturing operations for the comforter are as follows: China: Polyamide (nylon) and elastane yarn is formed. Yarns are exported to South Korea. South Korea: Polyamide (nylon) and elastane griege knitted fabric is formed. Polyamide (nylon) and elastane griege knitted fabric is exported to China. China: Batting, piping and sewing thread are formed. Griege knitted fabric formed in South Korea is shaped, dyed, washed, inspected. Finished fabrics are cut, assembled by sewing, and quilted. Finished reversible quilted comforters are bagged, sealed, and boxed for shipment 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:” The comforter is classified under subheading 9404.40.90, Harmonized Tariff Schedule of the United States (HTSUS). Prior to 2022, the corresponding HTSUS to subheading 9404.40.90 was subheading 9404.90.85. 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 classification, below. See New York Ruling Letter N338830. The sheets and pillowcases are classified under subheading 6302.10, HTSUS. 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. 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), in pertinent part, states: (2) 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 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. Each of the components of the sheet set are classified under subheading 6302.10, HTSUS. Subheading 6302.10, HTSUS, is not included in the paragraph (e)(2) exceptions to the above tariff shift rule. Therefore, as the flat sheet and pillowcases are made of fabric formed in a single country, territory, or insular possession, that is, South Korea, as per the terms of the tariff shift requirement, country of origin is conferred in South Korea. The fitted sheet is made of two fabrics formed in different countries; the nylon and elastane fabric is knit in South Korea, and the narrow-elasticized fabric is woven in China. In this case, however, the narrow woven elasticized fabric is disregarded in accordance with Section 102.13, the De Minimis rule. Section 102.21(c), "General Rules," inter alia, state the requirements or conditions of Sections 102.12 through 102.19, where appropriate, are applicable when determining origin under Section 102.21(c)(1) through (5). Section 102.13 "De Minimis," states the following, in pertinent part: (c) Foreign components or materials that do not undergo the applicable change in tariff classification set out in Section 102.21 or satisfy the other applicable requirements of that section when incorporated into a textile or apparel product covered by that Section shall be disregarded in determining the country of origin of the good if the total weight of those components or materials is not more than 7 percent of the total weight of the good. You have indicated that the narrow-elasticized fabric represents 6.7 percent of the weight of the finished fitted sheet. Therefore, as you have indicated the narrow-elasticized fabric woven in China does not constitute more than 7 percent of the total weight of the fitted sheet, the fabric is disregarded in determining the country of origin of the fitted sheet. As the remaining fabric comprising the fitted sheet is formed in a single country, that is, South Korea, as per the terms of the tariff shift requirement, country of origin is conferred in South Korea. Subheading 9404.90.85, HTSUS, is provided for in the paragraph (e)(2) exceptions. However, as the fabrics forming the comforter are not printed, paragraph (e)(2)(i) is inapplicable and as the fabrics are formed in more than one country, paragraph (e)(2)(ii) is also inapplicable. 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: (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 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 fabrics forming the comforter are not knit to shape and heading 9404.90 is excepted from paragraph (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 fabric-making process of the subject comforter’s outer shell constitutes the most important manufacturing process. See HQ 562498, dated November 13, 2002. Accordingly, the fabric-making process in South Korea, where the fabric for the outer shell is formed by knitting, constitutes the most important manufacturing process; therefore, the country of origin for the comforter is conferred in South Korea. HOLDING: The country of origin of the sheet set, SKU #REST-ISS01F, is conferred in South Korea pursuant to 19 CFR 102.21(c)(2). The country of origin of the comforter, SKU #REST-SCD00T-N, is conferred in South Korea pursuant to 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 P. Forkan Director National Commodity Specialist Division