Classification and country of origin determination for a chenille mat; 19 CFR 102.21(c)(3); wholly assembled

N360607 April 16, 2026 OT:RR:NC:N2:349 CATEGORY: Classification, Origin TARIFF NO.: 5702.42.2080 Ms. Fay Xu Evergrace Home Inc 5 Floor Sunshine Mansion, 2000 Pudong Avenue Shanghai 200135 China RE: Classification and country of origin determination for a chenille mat; 19 CFR 102.21(c)(3); wholly assembled Dear Ms. Xu: This is in reply to your letter dated April 10, 2026, requesting a classification and country of origin determination for a chenille mat, which will be imported into the United States. FACTS: The subject merchandise, Item #EG260410001, is described as a chenille mat. The surface of the mat consists of 100 percent polyester machine woven chenille fabric. The chenille fabric is laminated to a .5-inch-thick layer of memory foam and backed with polyvinyl chloride (PVC). The mat is finished along the edges with knitted binding. The mat measures 16 × 23 inches. The manufacturing operations for the mat are as follows: China: Woven chenille is formed. PVC is formed. Knitted binding is formed. Woven chenille fabric, PVC and knitted binding are exported to Vietnam. Vietnam: Foam is formed. Foam and PVC are laminated to woven chenille fabric. Laminated fabric is cut to size. Edges are finished with a knitted binding. Finished mat is packaged and exported to the United States. ISSUE: What are the classification and country of origin of the subject merchandise? CLASSIFICATION: The applicable subheading for the chenille mat will be 5702.42.2080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Carpets and other textile floor coverings, woven, not tufted or flocked, whether or not made up, including "Kelem", "Schumacks", "Karamanie" and similar handwoven rugs: Other, of pile construction, made up: Of man-made textile materials: Other: Other.” The general rate of duty will be Free. 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customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996.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 5701 - 5705 A change to 5701 through 5705 from any other chapter. In our opinion the woven chenille fabric has the thickness, stiffness and strength to render it suitable for use as a floor covering of heading 5702 prior to being laminated to the foam and PVC backing. Therefore, the foreign materials do not undergo the applicable tariff change in a single country, territory or insular possession. The chenille fabric makes the tariff shift in China and the foam, PVC and binding fabric make the tariff shift in Vietnam. As each foreign material does not undergo the applicable change in tariff classification in a single country, Section 102.21(c)(2) is inapplicable. Section 102.21(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 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. The term “wholly assembled” is defined under Section 102.21(b)(6) which states, (6) Wholly assembled. The term “wholly assembled” when used with reference to a good means that all components, of which there must be at least two, preexisted in essentially the same condition as found in the finished good and were combined to form the finished good in a single country, territory, or insular possession. Minor attachments and minor embellishments (for example, appliques, beads, spangles, embroidery, buttons) not appreciably affecting the identity of the good, and minor subassemblies (for example, collars, cuffs, plackets, pockets), will not affect the status of a good as “wholly assembled” in a single country, territory, or insular possession. As the subject merchandise is wholly assembled in a single country, that is, Vietnam, country of origin is conferred in Vietnam. HOLDING: Item #EG26040001 is classified under subheading 5702.42.2080, HTSUS. The country of origin of the mat is Vietnam pursuant to 19 CFR 102.21(c)(3)(ii). The tariffs and additional 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 Kim Wachtel at kimberly.a.wachtel@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division