N350592

N350592 July 16, 2025 OT:RR:NC:N3:348 CATEGORY: Classification, Origin TARIFF NO.: 6217.10.9530; 9903.01.25 Kristin Young Norman Krieger Inc 5000 East Spring Street Ste 250 Long Beach, CA 90815 RE: Classification and country of origin determination for an unfinished belt; 19 CFR 102.21(c)(5)); last country where an important assembly or manufacturing process occurred Dear Ms. Young: This is in reply to your letter dated June 24, 2025, requesting a classification and country of origin determination for unfinished belts on behalf of CFL Distribution, which will be imported into the United States. FACTS: The subject merchandise consists of two unfinished unisex fashion belts. Styles SC135 and SC136 measure approximately 59 inches in length and 1.5 inches in width. The strap, that encircles the waist, is constructed from 100% polyester narrow woven fabric. The ratchet strap is constructed from 100% polyurethane material. Style SC136 is ornamented with a woven polyester ribbon. The unfinished belts do not contain a buckle at the time of importation. The manufacturing operations are as follows: Unfinished belt – Style SC135 The embroidered polyester woven fabric is manufactured and cut to length in China or in Cambodia. The ratchet strap component is manufactured in Cambodia and sewn/attached to one end of the embroidered polyester strap in Cambodia. A buckle will be added after importation into the United States. Unfinished belt – Style SC136 The polyester woven fabric and polyester ribbon are manufactured and cut to length in China or Cambodia. A ratchet strap is manufactured in Cambodia and sewn/attached to one end of the ornamented polyester strap in Cambodia. A buckle will be added after importation into the United States. ISSUE: What are the classification and country of origin of the subject merchandise? CLASSIFICATION: The applicable subheading for Styles SC135 and SC136 will be 6217.10.9530, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other made-up clothing accessories; parts of garments or of clothing accessories, other than those of heading 6212: Accessories: Other: Other: Of man-made fibers. The general rate of duty will be 14.6 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 6215-6217 (1) If the good consists of two or more component parts, a change to an assembled good of heading 6215 through 6217 from unassembled components, provided that the change is the result of the good being wholly assembled in a single country, territory, or insular possession. As the unfinished belt is not wholly assembled in a single country, territory or insular possession, 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: 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 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 subject merchandise is neither knit to shape, nor wholly assembled in a single country, 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, as the single country, territory, or insular possession in which the most important assembly or manufacturing operation occurred cannot be determined, Section 102.21 (c)(4) is not applicable. 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 belts, the country of origin is conferred by the last country in which an important assembly or manufacturing process occurred, that is, Cambodia. HOLDING: The country of origin of the unfinished belts is Cambodia. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries, including Cambodia, will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, 9903.01.25, in addition to subheading 6217.10.9530, HTSUS, listed above. 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 

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 6215-6217 (1) If the good consists of two or more component parts, a change to an assembled good of heading 6215 through 6217 from unass