RE: Classification and country of origin determination for pet toys; 19 CFR 102.21(c)(2); tariff shift

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364427 September 16, 2026 OT:RR:NC:N3:351 CATEGORY: Classification, Origin TARIFF NO.: 6307.90.7500 Mr. Jong Whi Pak OEC Group New York 5 Dakota Drive, Suite 200 New Hyde Park 11042 RE: Classification and country of origin determination for pet toys; 19 CFR 102.21(c)(2); tariff shift Dear Mr. Pak: In your letter dated August 20, 2026, you requested a classification and country of origin determination for pet toys on behalf of your client, CityPets US LLC. A sample of each pet toy was provided with your request. Item #84597-0007, described as a “Lobster Plush Toy,” is a knotted rope and stuffed fabric pet toy designed for chewing and sensory play with a dog. The lobster-shaped pet toy is comprised of two knotted rope “feelers” stitched to the head of the lobster and three knotted rope “legs” inserted through the main body of the lobster creating six “legs.” Each 4-inch “Feeler” and 10-inch “Leg” is composed of blue and white rope twisted together and knotted at the end to prevent unraveling. The rope consists of a combination of 75 percent cotton and 25 percent polyester staple dyed yarns and 100 percent polyester staple dyed yarns. The lobster body is composed of 100 percent polyester plush knitted fabric, dyed red and stuffed with 100 percent polyester fiberfill. The lobster body, measuring 9 inches in length by 7 inches in width, features an internal squeak mechanism and embroidered eyes, a smile, and an anchor motif located above the tail section. The lobster tail, measuring 2 inches in length by 4 ½ inches in width, consists of 100 percent polyethylene terephthalate (PET) crinkle paper sandwiched between two layers of 100 percent polyester plush knitted printed fabric. The completed pet toy measures 12 inches in length by 10 inches in width. Item #83834-0005, described as a “Rabbit Plush Toy,” consists of a stuffed fabric figure threaded through the hollow center of a translucent, thermoplastic rubber (TPR) spiky ball designed for chewing and sensory play with a dog. The rabbit-shaped figure is composed of 100 percent polyester ribbed corduroy woven fabric, dyed tan and stuffed with 100 percent polyester fiberfill. The rabbit figure measuring 13 inches in length by 8 inches in width features a nonwoven fabric tooth, brown plush knitted fabric hands and feet, an internal squeak mechanism, and embroidered eyes and a nose. The TPR spiky ball has a diameter of 3 ¼ inches. The completed pet toy measures 13 inches in length by 8 inches in width by 3 ¼ inches in depth. You state the manufacturing operations for the pet toys are as follows: Lobster Plush Toy: China: Feelers and legs: 100 percent polyester staple yarns are produced, dyed, and spooled. Feelers and legs: 75 percent cotton and 25 percent polyester staple yarns are produced, dyed and spooled. Feelers and legs: the 100 percent polyester yarns are combined with 75 percent cotton and 25 percent polyester yarns, twisted into a rope, and shipped to Indonesia. Body: The 100 percent polyester plush fabric is knitted, dyed, and shipped in rolls to Indonesia. 100 percent polyester fiber fill is produced and shipped in bales to Indonesia. The PET crinkle paper is produced and shipped to Indonesia. Indonesia: The 100 percent polyester staple yarns for sewing and embroidery are produced. The squeaker, stuff label, and paper hangtag are produced. The rope is cut to size for feelers and legs. The fabric is cut and sewn to form the lobster body and tail. The lobster body is stuffed with fiberfill, embroidered, and rope “legs” are inserted through the body, and sewn closed. The rope “feelers” are sewn to the head of the lobster. The rope “feelers” and “legs” are knotted to prevent unraveling. PET crinkle paper is inserted in between the tail fabric and sewn to the lobster body. The completed dog toy is packaged and shipped to the United States. Rabbit Plush Toy: China: Body: 100 percent polyester ribbed corduroy fabric is woven, dyed, and shipped in rolls to Indonesia. Hands, Feet, and Inner ears: 100 percent polyester plush fabric is knitted, dyed, and shipped in rolls to Indonesia. Tooth: 100 percent polyester nonwoven fabric is produced and shipped in rolls to Indonesia. 100 percent polyester fiber fill is produced and shipped in bales to Indonesia. The TPR spiky ball is produced and shipped to Indonesia. Indonesia: 100 percent polyester staple yarns for sewing and embroidery are produced. The squeaker, stuff label, and paper hangtag are produced. The fabric is cut and sewn to form the rabbit’s body, hands, feet, inner ears, and tooth. The rabbit is stuffed with fiberfill. The TPR spiky ball is passed through the rabbit’s body. The completed dog toy is packaged and shipped to the United States. ISSUE: What are the classification and country of origin of the subject merchandise? CLASSIFICATION: The lobster plush pet toy and rabbit plush pet toy are both composite goods. The lobster plush toy consists of textile cordage (Chapter 56) and a made up textile article (heading 6307). The rabbit plush toy consists of a made up textile article (heading 6307) and a TPR ball (heading 3924). General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States, (HTSUS), states in part that for legal purposes, classification shall be determined according to the terms of the headings, any relative section or chapter notes and, unless otherwise required, according to the remaining GRI’s taken in order. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3. GRI 3(a) states that the heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings refer to part only of the items in a composite good, those headings are to be regarded as equally specific in relation to the goods, even if one of them gives a more complete or precise description of the good. As such, they are regarded as equally specific and classification of the composite good is to be determined by GRI 3(b) or GRI 3(c). GRI 3(b) states in part that composite goods, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. In this case, we find the essential character of the rabbit plush pet toy is imparted by the textile fabric; consequently, it is classified in heading 6307, HTSUS. In regard to the lobster plush pet toy, the essential character of the pet toy cannot clearly be ascribed to any single component. Therefore, pursuant to GRI 3(c), HTSUS, the lobster plush pet toy will be classifiable under heading 6307, HTSUS, which occurs last in numerical order among those which equally merit consideration. The applicable subheading for the pet toys will be 6307.90.7500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other made-up articles, including dress patterns: Other: Toys for pets, of textile materials.” The general rate of duty will be 4.3 percent ad valorem. 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 6307 The country of origin of a good classifiable under 6307.90 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 “any manufacturing operation that begins with polymers, fibers, filaments (including strips), yarns, twine, cordage, rope, or fabric strips and results in a textile fabric.” Accordingly, as the fabrics for the pet toys were manufactured in China, as per the terms of the tariff shift rule for heading 6307, HTSUS, the country of origin of the pet toys, including for purposes of determining the application of Section 301 duties, is China. HOLDING: The applicable subheading for the pet toys will be 6307.90.7500, HTSUS. The country of origin for the pet toys is China, pursuant to 19 CFR 102.21(c)(2). 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/. 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