N349253

N349253 June 6, 2025 OT:RR:NC:N2:349 CATEGORY: Classification, Origin TARIFF NO.: 6301.40.0020; 9903.01.25 Mr. Ping Gao E&E Co. Ltd. 45875 Northport Loop East, Building B Fremont, CA 94587 RE: Classification and country of origin determination for quilted blanket; 19 CFR 102.13; De Minimis; 19 CFR 102.21(c)(5); last country where an important assembly or manufacturing process occurred Dear Mr. Gao: This is in reply to your letter dated May 20, 2025, requesting a classification and country of origin determination for a quilted blanket, which will be imported into the United States. A sample of the quilted blanket was submitted with your request and will be retained by this office for training purposes. FACTS: The subject merchandise, “Cooling Touch Down Alternative Throw,” is a quilted blanket comprised of three layers: two fabrics and fiberfill. The face side is composed of 77 percent nylon and 23 percent polyethylene, dyed, knitted fabric and the reverse side is composed of 100 percent polyester, dyed, woven fabric. Polyester fiberfill is stuffed between the two fabrics. The three layers are quilted together in a wavy block pattern. The blanket measures 50 x 60 inches and is finished along the edges with 100 percent polyester brushed knit binding. It will be packaged and imported for retail sale with a single ribbon with hook and loop tabs. You state that the item is intended for indoor use to provide warmth to an individual. The manufacturing operations for the quilted blanket are as follows: China Nylon/polyethylene face fabric is knitted and dyed. Knitted nylon/polyethylene face fabric is shipped in rolls to Pakistan. Pakistan Polyester backing fabric is woven and dyed. Polyester fiberfill material is formed. Polyester brushed knit binding is formed. Fabrics are cut, assembled by sewing, filled and quilted. Finished quilted blankets are exported to the United States. ISSUE: What are the classification and country of origin of the subject merchandise? CLASSIFICATION: The applicable subheading for “Cooling Touch Down Alternative Throw” will be 6301.40.0020, HTSUS, which provides for blankets (other than electric blankets) and traveling rugs, of synthetic fibers, other. The general rate of duty will be 8.5 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 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 the 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. The quilted blanket is made from three fabrics formed in two different countries. The face fabric is formed in China and the backing and binding fabrics are formed in Pakistan; however, the binding fabric is disregarded in accordance with Section 102.13, the De Minimis rule. Section 102.21(c), "General Rules," inter alia, states 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. With respect to the quilted blanket, you state the binding fabric represents .60 percent of the total weight. Consequently, the binding fabric is disregarded when determining the country of origin of the quilted blanket. However, as the face and backing fabrics are not formed in a single country, Section 102.21(c)(2) is 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 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, 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 subject merchandise is not knit to shape, and is excepted from paragraph (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.” In the case of the subject merchandise, the most important manufacturing process occurs at the time of fabric making. The fabrics for the instant item are sourced in more than one country. As no one fabric is more important than the other, a single country of origin determination cannot be made based on Section 102.21(c)(4). 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, in the case of the subject quilted blanket, the country of origin i

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 g