N336815

N336815 December 19, 2023 OT:RR:NC:N3:351 CATEGORY: Country of Origin; Marking Mr. Shuchuan Henson Deng Recreational Equipment Inc. 1700 45th Street East, Suite 101 Sumner, WA 98352 RE: Country of origin and marking determination for tents from China and Vietnam; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.21 (c)(5); last country in which an important assembly or manufacturing process occurs; Section 301 duties Dear Mr. Henson Deng: This is in reply to your letter dated November 29, 2023, requesting a country of origin and marking determination for five styles of imported tents. In lieu of samples, photographs of the tents were provided with your request. SKU# 24963/227864, described as a “Skyward OA Tent,” is a 4-person outdoor folding tent. The tent is composed of manmade textile materials. The tent has a net weight of 13 pounds 11 ounces, a floor area of 60 ½ square feet, standing height of 78 inches, and a carry size dimension of 27 ½ inches in length by 9 ¾ inches in width by 9 ¾ inches in height. The tent is imported together with a stuff sack that houses the tent, vestibule, rainfly, poles, and stakes. SKU#25247/227867, described as a “Wonderland 6 Titanium Tent,” is a 6-person outdoor folding tent. The tent is composed of manmade textile materials. The tent has a net weight of 25 pounds 16 ounces, a floor area of 83 ¼ square feet, standing height of 78 inches, and a carry size dimension of 32 inches in length by 13 inches in width by 13 inches in height. The tent is imported together with a stuff sack that houses the tent, vestibule, rainfly, poles, and stakes. SKU#24649/227863, described as a “Campwell Tent” is a 4-person outdoor folding tent. The tent is composed of manmade textile materials. The tent has a net weight of 13 pounds, a floor area of 61.11 square feet, standing height of 62 inches, and a carry size dimension of 27 ½ inches in length by 9 ½ inches in width by 9 ½ inches in height. The tent is imported together with a stuff sack that houses the tent, rainfly, poles, and stakes. SKU# 24662/227740, described as a “Base Camp 4,” is a 4-person outdoor folding tent. The tent is composed of manmade textile materials. The tent has a net weight of 17 pounds and 5.6 ounces, a floor area of 59.72 square feet, standing height of 63 inches, and a carry size dimension of 20 ¼ inches in length by 9 ¾ inches in width by 9 ¾ inches in height. The tent is imported together with a stuff sack that houses the tent, rainfly, poles, and stakes. SKU# 24663/227904, described as a “Base Camp 6,” is a 6-person outdoor folding tent. The tent is composed of manmade textile materials. The tent has a net weight of 20 pounds and 11.5 ounces, a floor area of 84.38 square feet, standing height of 74 inches, and a carry size dimension of 23 ¾ inches in length by 10 ¾ inches in width by 10 ¾ inches in height. The tent is imported together with a stuff sack that houses the tent, rainfly, poles, and stakes. You state the pertinent manufacturing operations for the “Skyward OA,” “Wonderland 6 Titanium,” “Campwell,” “Base Camp 4,” and “Base Camp 6” tent is as follows: South Korea: • Skyward OA: o Front and back side wall bug mesh and roof mesh, C: 100 percent nylon mesh fabric is knitted, dyed, and shipped in rolls to Vietnam. o Aluminum poles are produced and shipped to Vietnam. • Wonderland 6 Titanium: o Bug mesh, C: 100 percent nylon mesh fabric is knitted, dyed, and shipped in rolls to Vietnam. o Aluminum poles are produced and shipped to Vietnam. • Campwell: o Canopy mesh, D: 100 percent nylon mesh fabric is knitted, dyed, and shipped in rolls to Vietnam. • Base Camp 4 & 6: o Bug mesh, C: 100 percent nylon mesh fabric is knitted, dyed, and shipped in rolls to China. o Aluminum poles are produced and shipped to China. Taiwan: • Skyward OA: o Stuff sack: 100 percent polyester fabric is woven, dyed, coated with a water repellant finish, impregnated with polyurethane (PU) on one side, and shipped to Vietnam. o Pole and stake bag- 100 percent polyester fabric is woven, dyed, coated with PU, and shipped to Vietnam. • Wonderland 6 Titanium: o Floor, D- 100 percent polyester fabric is woven, dyed, coated with a water repellant finish, impregnated with PU on one side, and shipped to Vietnam. o Stuff sack: 100 percent polyester fabric is woven, dyed, coated with a water repellant finish, impregnated with PU on one side and shipped to Vietnam. o Pole and stake bag: 100 percent polyester fabric is woven, dyed, coated with PU, and shipped to Vietnam. China: • Skyward OA: o Rainfly Roof, vestibule roll-up loops, stake and pole bags, E: 100 percent polyester fabric is woven, dyed, coated with a water repellant finish, impregnated with PU on one side, and shipped in rolls to Vietnam. o Front side wall panel, B: 100 percent polyester fabric is woven, dyed, coated with water repellant finish, and shipped in rolls to Vietnam. o Left, right, and back Side wall panel, A: 100 percent polyester fabric is woven, dyed, coated with a water repellant finish, impregnated with PU on one side, and shipped in rolls to Vietnam. o Floor, D- 100 percent polyester fabric is woven, dyed, coated with a water repellant finish, impregnated with PU on one side, and shipped in rolls to Vietnam. o Stakes, zippers, guy lines, thread, grommets, plastic hardware, and webbing straps are produced and shipped to Vietnam. • Wonderland 6 Titanium: o Stakes, guy lines, thread, grommets, plastic hardware, webbing straps are produced and shipped to Vietnam. • Campwell: o Tent body, rainfly A: 100 percent polyester fabric woven, dyed, coated with water repellant finish, impregnated with PU on one side, and shipped in rolls to Vietnam. o Floor, C: 100 percent polyester woven, dyed, coated with water repellant finish, impregnated with PU on one side, and shipped in rolls to Vietnam. o Stuff sack: 100 percent polyester fabric is woven, dyed, coated with a water repellant finish, impregnated with PU on one side, and shipped to Vietnam. o Stake and pole bag: 100 percent polyester fabric is woven, dyed, impregnated with PU on one side, and shipped in rolls to Vietnam. o Stakes, zippers, guy lines, thread, grommets, fiberglass poles, plastic hardware, webbing straps are produced and shipped to Vietnam. • Base Camp 4 & 6 o Rainfly (main fabric, accents, binding), inner front binding, floor rollup loops, stuff sack accent, inner tent gear loops, main corner pole sleeves, and pocket binding, A: 100 percent polyester fabric woven, dyed, coated with water repellant finish, impregnated with PU on one side, and shipped in rolls. o Breathable wall fabric, B: 100 percent polyester fabric woven, dyed, and coated with water repellant finish, and shipped in rolls. o Floor, floor binding, and door wall pole sleeves, D: 100 percent polyester fabric, woven, dyed, coated with water repellant finish, impregnated with PU on one side, and shipped in rolls. o Stuff sack: 100 percent polyester fabric is woven, dyed, coated with a water repellant finish, impregnated with PU on one side, and shipped in rolls. o Pole and stake bag: 100 percent polyester fabric is woven, dyed, coated with PU, and shipped in rolls. o Stakes, zippers, guy lines, thread, grommets, plastic hardware, webbing straps are produced and shipped. o Fabric is cut to shape and size. o Fabric is sewn and hemmed to create a tent, rainfly, stuff sack, pole bag, and stake bag. o The completed tent is assembled and disassembled. o The tent poles are placed into a pole bag. o The guy cords are placed into the stake bag. o The stakes are placed into a stake bag. o All components are placed in the respective stuff sack. o A hang tag is attached to the stuff sack. o The tents are packaged in cartons and shipped to the United States. Hong Kong: • Skyward OA: o Seam tape is produced and shipped to Vietnam. • Wonderland 6 Titanium: o Seam tape is produced and shipped to Vietnam. • Campwell: o Seam tape is produced and shipped to Vietnam. Vietnam: • Skyward OA: o Fabric is cut to shape

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 textile and apparel products entered, or withdrawn from warehouse for consumption on and after July 1, 1996.  Section 334 of the URAA was amended by section 405 of title IV of the Trade and Development Act of 2000, Public Law 106-200, 114 Stat. 251.  Section 102.21 of Title 19 of the Code of Federal Regulations (19 C.F.R. § 102.21), implements the URAA.  Thus, the country of origin of a textile or apparel product will be determined by the sequential application of the general rules set forth in paragraphs (c)(1) through (5) of section 102.21 and, where appropriate to the specific context, by application of the additional requirements or conditions of section 102.12 through 102.19 of this part.  Section 102.15(a)(1) instructs Customs to disregard packaging materials and containers in which a good is packaged for retail sale that are classified with the good when determining whether the good undergoes the applicable change in tariff classification set out in Section 102.21.  Since the sack bag has been determined to be a container in which the tent is packaged for retail sale and classified with the tent, the sack bag fabric is not considered when determining the origin of the tent.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