N347636

N347636 May 5, 2025 OT:RR:NC:N2:349 CATEGORY: Classification, Origin TARIFF NO.: 5702.42.2080; 5705.00.2030; 9903.01.24; 9903.01.25; 9903.01.63; 9903.88.03 Fay Xu Evergrace Home Inc 5 Floor Sun Shine Mansion, 2000 Pudong Avenue Shanghai 200135 China RE: Classification and country of origin determination for floor mats; 19 CFR 102.21(c)(2); tariff shift Dear Ms. Xu: This is in reply to your letter dated April 10, 2025, requesting a classification and country of origin determination for two floor mats, which will be imported into the United States. FACTS: Item# EG2503010, which you describe as a “printed chenille bathmat,” is a woven floor mat consisting of an exposed upper surface of a 100 percent polyester, chenille woven fabric printed with primitive diamond shaped designs. A nonwoven fabric is laminated to the back of the chenille face. These two layers are laminated to a backing of canvas coated with thermoplastic rubber (TPR) on the bottom surface to provide a non-skid surface. The edges are finished with an overlock stitch. The mat measures 18 ½ x 27 inches and is approximately 1/16 inch thick. Item# EG2503011, which you describe as a “faux cashmere bathmat,” is a bathmat consisting of an exposed upper surface of 100 percent polyester knitted fabric of cut pile construction. The surface is printed with an oriental design. The knitted fabric is laminated to a layer of foam, approximately 3/8 inch thick, and is backed with a nonwoven fabric with an application of polyvinyl chloride (PVC) dots forming a design. The edges are finished with knitted binding tape. The bathmat measures 20 × 32 inches. The manufacturing operations for Item# EG2503010, the chenille mat, are as follows: SCENARIO 1 China Chenille fabric is woven. Nonwoven fabric is formed. Canvas is formed. Nonwoven fabric is laminated to the woven chenille fabric. Vietnam Canvas is coated with TPR. TPR coated canvas is laminated to the back of the nonwoven fabric. Chenille fabric is printed. Fabric is cut to size. All the edges are finished with an overlock stitch. Completed mat is packaged and exported to the United States. SCENARIO 2 China Chenille fabric is woven. Nonwoven fabric is formed. Canvas is formed. Nonwoven fabric is laminated to the woven chenille fabric. Canvas is coated with TPR. TPR coated canvas is laminated to the back of the nonwoven fabric. Vietnam Chenille fabric is printed. Fabric is cut to size. All the edges are finished with an overlock stitch. Completed mat is packaged and exported to the United States. SCENARIO 3 China Chenille fabric is woven. Nonwoven fabric is formed. Canvas is formed. Nonwoven fabric is laminated to the woven chenille fabric. Canvas is coated with TPR. TPR coated canvas is laminated to the back of the nonwoven fabric. Chenille fabric is printed. Vietnam Fabric is cut to size. All the edges are finished with an overlock stitch. Completed mat is packaged and exported to the United States. The manufacturing operations for Item# EG2503011, the faux cashmere bathmat, are as follows: SCENARIO 1 China Pile face fabric (faux cashmere) is knit. Foam is formed. Nonwoven is formed and PVC anti-slip dots applied. Vietnam Foam, nonwoven with anti-slip dots and knit pile face fabric are laminated together. Knit pile face fabric is printed. Binding is knit. Fabric is cut to size. All the edges are finished with a knit binding. The completed bathmat is packaged and exported to the United States. SCENARIO 2 China Pile face fabric (faux cashmere) is knit. Foam is formed. Nonwoven is formed and PVC anti-slip dots applied. Foam, nonwoven with anti-slip dots and knit pile face fabric are laminated together. Vietnam Knit pile face fabric is printed. Binding is knit. Fabric is cut to size. All the edges are finished with a knit binding. The completed bathmat is packaged and exported to the United States. SCENARIO 3 China Pile face fabric (faux cashmere) is knit. Foam is formed. Nonwoven is formed and PVC anti-slip dots applied. Foam, nonwoven with anti-slip dots and knit pile face fabric are laminated together. Knit pile face fabric is printed. Vietnam Binding is knit. Fabric is cut to size. All the edges are finished with a knit binding. The completed bathmat 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 Item# EG2503010, 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. The applicable subheading for Item# EG2503011, the faux cashmere bathmat, will be 5705.00.2030, HTSUS, which provides for “Other carpets and other textile floor coverings, whether or not made up: Other: Of man-made fibers.” The general rate of duty will be 3.3 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 5701-5705 A change to heading 5701 through 5705 from any other chapter. Item# EG2503010, the chenille mat, meets the tariff shift in the country where the TPR coated canvas is laminated to the back of the nonwoven fabric which has already been laminated to the face fabric. As a result, as per the terms of the tariff shift, country of origin is conferred in Vietnam under Scenario 1 and China under Scenarios 2 and 3. Item# EG2503011, the faux cashmere bathmat, meets the tariff shift in the country where the foam, nonwoven with anti-slip dots and knit pile face fabric are laminated together. As a result, as per the terms of the tariff shift, country of origin is conferred in Vietnam under Scenario 1 and China under Scenarios 2 and 3. HOLDING: Item# EG2503010, the chenille mat, is classified under 5702.42.2080, HTSUS, and the country of origin is Vietnam under Scenario 1 and China under Scenarios 2 and 3. Item# EG2503011, the faux cashmere bathmat, is classified under 5705.00.2

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 heading 5701 through 5705 from any other chapter. Item# EG2503010, the chenille mat, meets the tariff shift in the