N349547

N349547 June 24, 2025 OT:RR:NC:N2:349 CATEGORY: Origin Ms. Sandy Ye Multi Glory USA Corporation 11345 Fellows Creek Drive Plymouth, MI 48170 RE: Country of origin determination for quilted mattress pads and bed rest pillow cover; 19 CFR 102.21(c)(5); last country where an important assembly or manufacturing process occurred Dear Ms. Ye: This is in reply to your letter dated May 29, 2025, requesting a country of origin determination for two mattress pads and a bed rest pillow cover, which will be imported into the United States. In lieu of samples, photographs were submitted with your request. FACTS: Style #586934257, described as “Total Protection Waterproof MP Q,” is a queen size quilted mattress pad made of five layers. The top layer (layer 1) of the mattress pad is made from 100 percent polyester microfiber plain woven fabric treated with Scotchgard and Microban antimicrobial. This layer is followed by 100 percent polyester nonwoven batting, also treated with Microban antimicrobial (layer 2), and 100 percent polyester nonwoven fabric (layer 3). The bottom two layers, a nonwoven fabric laminated to thermoplastic polyurethane (TPU) serve as a waterproof barrier. The top three layers are quilted together. Sewn to the body of the mattress pad is a fully elasticized skirt made from 100 percent polyester weft knit fabric. The mattress pad measures 60 x 80 inches. The mattress pad is packaged and sold at retail. Style #586934213, described as “Waterproof Mattress Pad Q,” is a queen size ultrasonically quilted mattress pad made of five layers. The top layer (layer 1) of the mattress pad is made from 100 percent polyester weft knit fabric treated with Scotchgard and Microban antimicrobial. This layer is followed by 100 percent polyester nonwoven batting (layer 2) and 100 percent polyester nonwoven fabric (layer 3). The bottom two layers, a nonwoven fabric laminated to thermoplastic polyurethane (TPU) serve as a waterproof barrier. The top three layers are quilted with a pinsonic pattern. Sewn onto the body of the mattress pad is a fully elasticized skirt made from 100 percent polyester weft knit fabric. The mattress pad measures 60 x 80 inches. The mattress pad is packaged and sold at retail. Style #MGBR2426, described as “Bedrest,” is a pillow cover for a bedrest pillow. The front of the pillow cover is made from dyed 100 percent polyester faux fur knit pile fabric laminated to 100 percent polypropylene nonwoven fabric. The back is made of dyed 100 percent polyester micro mink knit pile fabric. The pillow cover features a zipper closure at the bottom, 14 ½ inch long arm rests on the outer sides and a handle on the top center edge for easier carrying. The pillow cover measures 17 inches in height and 27 inches in width. You state that the cover will be filled with 100 percent polyester fiberfill in the United States, packaged and sold at retail as a finished bedrest pillow. The manufacturing operations for the “Total Protection Waterproof MP Q,” style #586934257, are as follows: China Yarns for the top fabric are produced. Polyester nonwoven (layer 3) is formed. Waterproof barrier (nonwoven fabric laminated to TPU) is formed. Polyester knit skirt fabric is formed. Elastic, care labels and law labels are made. Yarn, fabrics (on rolls), elastic, and labels are shipped to Vietnam. Vietnam Polyester microfiber top fabric (layer 1) is woven, bleached and finished. Polyester batting (layer 2) is formed. Thread is produced. Fabrics are cut. Fabrics are quilted (layers 1, 2 and 3). Components are assembled by sewing. The finished mattress pad is tested, inspected, packaged, warehoused, and exported into United States. The manufacturing operations for the “Waterproof Mattress Pad Q,” style #586934213 are as follows: China Polyester top fabric (layer 1) is formed by knitting, bleached and finished. Polyester nonwoven fabric (layer 3) is formed. Waterproof barrier (nonwoven fabric laminated to TPU) is formed. Elastic, care labels and law labels are made. Fabric (on rolls), elastic, and labels are shipped to Vietnam. Vietnam Polyester skirt fabric is knit. Polyester batting (layer 2) is formed. Thread is produced. Fabrics are cut. Fabrics are ultrasonically quilted (layers 1, 2 and 3). Components are assembled by sewing. The finished mattress pad is tested, inspected, packaged warehoused and exported into United States. The manufacturing operations for the “Bedrest” pillow cover, style #MGBR2426, are as follows: China Polyester faux fur pile front fabric is knit and dyed. Polypropylene nonwoven fabric is formed. Polyester faux fur knit pile fabric and polypropylene nonwoven fabric are laminated. Zippers and labels are made. Faux fur knit pile laminated fabric on rolls, zippers and labels are exported to Vietnam. Vietnam Polyester micro mink plush back fabric is knit and dyed. Fabrics are cut and assembled by sewing into finished bedrest pillow cover with handle. The bedrest pillow cover is packaged and exported into United States. United States Polyester fiberfill is produced. Pillow covers are filled, zipped closed, packaged and shipped to U.S. customer. ISSUE: What is country of origin of the subject merchandise? 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:” Initially, we find that the bedrest pillow cover is classified under subheading 6304.91, Harmonized Tariff Schedule of the United States (HTSUS). The mattress pads are classified under subheading 9404.90.96, HTSUS. Prior to 2022, the corresponding HTSUS to subheading 9404.90.96 was subheading 9404.90.95. Paragraph (e)(2) of Section 102.21 has not been updated with the current tariff subheadings. Therefore, we follow the rule, below, corresponding to the prior classification. See New York Ruling Letter N338830. 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 a fabric-making process. 9404.90 Except for goods of subheading 9404.90 provided for in paragraph (

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:” Initially, we find that the bedrest pillow cover is classified under subheading 6304.91, Harmonized Tariff Schedule of the United States (HTSUS). The mattress pads are classified under subheading 9404.90.96, HTSUS. Prior to 2022, the corresponding HTSUS to subheading 9404.90.96 was subheading 9404.90.95. Paragraph (e)(2) of Section 102.21 has not been updated with the curr