N351508

N351508 August 13, 2025 OT:RR:NC:N2:349 CATEGORY: Origin Ms. Yoyo Yu Qingdao Smartex Home Textiles Co., Ltd. No.32 Xianggang Zhong Road Qingdao 266071 China RE: Country of origin determination for a duvet cover set and a decorative pillow; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.21(c)(5); last country where an important assembly or manufacturing process occurred Dear Ms. Yu: This is in reply to your letter dated July 21, 2025, requesting a country of origin determination for a duvet cover and sham set and a decorative pillow, which will be imported into the United States. In lieu of samples, a photograph was provided to this office. FACTS: Item 1, Style# VSCL-3D, described as a “Duvet Cover Set,” consists of a duvet and two pillow shams. Both the duvet cover and pillow shams have a face panel made from 100 percent cotton, yarn-dyed, woven chambray fabric and a back panel of 100 percent cotton woven fabric that is dyed. You state the fabrics have also been subjected to shrinking and permanent stiffening. The back fabric is bleached before dyeing. Neither fabric is printed. The duvet cover is not quilted, nor does it contain any embroidery, lace, braid, edging, trimming, piping or applique work. The duvet cover has a knife edge and features an opening at the bottom with a zipper closure. The sham is made from the same face and back fabrics as the duvet cover. It includes fringed trim inserted into the seam along the edges. The sham also features an opening at the bottom with a zipper closure. It does not contain any embroidery, lace, braid, edging, piping or applique work. The duvet cover and two-piece sham set are offered in Queen (92” x 96”) with Standard shams (20” x 26”) and King (110” x 96”) with King shams (20” x 36”) sizes. All of the components of the set are packaged with a ribbon and polyethylene (PE) bag. The duvet cover and shams are also packaged and sold separately at retail. Item 2, Style# VSCL-3P, described as a “Decorative Pillow,” is a decorative pillow cover with a stuffed pillow insert. The outer cover of the decorative pillow consists of a face panel made from 100 percent cotton, yarn-dyed, woven chambray fabric and a back panel made of 100 percent cotton woven fabric that is dyed. You state the fabrics have also been subjected to shrinking and permanent stiffening. The back fabric is bleached before dyeing. The decorative pillow cover has fringed trim along the edges and an opening at the bottom with a zipper closure. The pillow cover includes a removable pillow insert consisting of a 100 percent cotton woven outer shell that is stuffed with 100 percent polyester fiberfill and sewn closed on four sides. The decorative pillow measures 26 × 26 inches and is sold separately at retail. The manufacturing operations for the duvet and two-piece sham set are as follows: United States Cotton fibers are produced. Cotton fibers are shipped to China. China Cotton fibers are spun into a yarn and dyed. Dyed yarn is woven into chambray face fabric. Face fabric is further processed by shrinking and permanent stiffening. Cotton trim is woven. Zipper is formed. Fabric and trim in rolls, yarn for back, zippers and packaging material are shipped to Indonesia. Indonesia Greige cotton back fabric is woven. Sewing thread is formed. Fabric back panel is bleached, dyed, shrunk and permanently stiffened. Fabric is cut into panels to product size specifications. The panels are sewn into a sham and duvet cover with the zipper closure. Duvet cover and shams are finished, packaged and exported to the United States. The manufacturing operations for the decorative pillow are as follows: United States Cotton fibers are produced. Cotton fibers are shipped to China. China Cotton fibers are spun into a yarn and dyed. Face and back fabric are woven. Cotton trim is woven. Zipper is formed. Fabric and trim in rolls, yarn for pillow insert, zipper and packaging material are shipped to Indonesia. Indonesia Sewing thread is formed. Face and back fabric are cut into panels to product size specifications. The fabric panels are sewn into a pillow cover with an opening on the bottom and a zipper closure. Yarn is woven into greige cotton woven fabric for pillow insert. Fabric is cut and assembled into cotton cover shell and stuffed with a polyester fiberfill. All four sides on the cover shell are sewn closed into a finished pillow insert. The decorative pillow cover is stuffed with the pillow insert to form a finished pillow. Finished decorative pillow is packaged and exported to the United States. ISSUE: What is the 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). At the outset, we consider the duvet cover and shams a set, when packaged and imported for sale together, under the General Rules of Interpretation (GRI). Section 102.21(d) addresses the treatment of sets for country of origin purposes. Section 102.21(d) provides the following: Where a good classifiable in the HTSUS as a set includes one or more components that are textile or apparel products and a single country of origin for all of the components of the set cannot be determined under paragraph (c) of this section, the country of origin of each component of the set that is a textile or apparel product shall be determined separately under paragraph (c) of this section. Per the terms of 19 CFR 102.21(d), the country of origin of each item in the set must be determined separately if there is no single country of origin for the entire set. 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 a fabric-making process. 9404.90 Except for goods of subheading 9404.90 provided for in paragraph (e)(2) of this section, the country of origin of a good classifiable under subheading 9404.90 is the country, territory, or insular possession in which the fabric comprising the good was formed by a fabric-making process. The “fabric-mak

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). At the outset, we consider the duvet cover and shams a set, when packaged and imported for sale together, under the General Rules of Interpretation (GRI). Section 102.21(d) addresses the treatment of sets for country of origin purposes. Section 102.21(d) provides the following: Where a good classifiable in the HTSUS as a set includes one or more components that are textile or apparel products and a single country of origin for all of the components of the set cannot be determined under paragraph (c) of this section, the country of origin of each component of the set that is a textile or apparel product shall be determined separately under paragraph (c) of this section. Per the terms of 19 CFR 102.21(d), the country of origin of each item in the set must be determined separately if there is no single country of origin for the entire set. 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 1