N352382

N352382 September 4, 2025 OT:RR:NC:N3:351 CATEGORY: Classification, Country of Origin TARIFF NO.: 6306.22; 6307.90.9891; 9903.01.24; 9903.01.25; 9903.02.69; 9903.88.15 Mr. Adam Eimers Big Agnes, Inc 840 Yampa Street Steamboat Springs, CO 80487 RE: The tariff classification and country of origin determination for tents and mesh insert; 19 CFR 102.21 (c)(2); 19 CFR 102.21(c)(5) Dear Mr. Eimers: This is in reply to your letter dated August 13, 2025, requesting a country of origin determination for four tents and a mesh insert. In lieu of samples, photographs of the tents and mesh insert were provided with your request. SKU# TBH425, described as a “Big House 4,” is a 4-person outdoor folding tent with a backpack. The tent is composed of manmade textile materials. The tent has a net weight of 12.65 pounds, a floor area of 57 square feet, and a standing height of 70 inches. The tent is imported together with a backpack that houses the tent, rainfly, poles, and stakes. The backpack dimensions are 26 inches in length by 16 inches in width by 7 inches in height. SKU# TBH625, described as a “Big House 6,” is a 6-person outdoor folding tent with a backpack. The tent is composed of manmade textile materials. The tent has a net weight of 16.34 pounds, a floor area of 89 square feet, and a standing height of 80 inches. The tent is imported together with a backpack that houses the tent, rainfly, poles, and stakes. The backpack dimensions are 26 inches in length by 16 ½ inches in width by 8 inches in height. SKU# TBUNK425, described as a “Bunk House 4,” is a 4-person outdoor folding tent with a backpack. The tent is composed of manmade textile materials. The tent has a net weight of 15.01 pounds, a floor area of 58 square feet, and a standing height of 72 inches. The tent is imported together with a backpack that houses the tent, rainfly, poles, and stakes. The backpack dimensions are 26 ½ inches in length by 16 ½ inches in width by 6 inches in height. SKU# TBUNK625, described as a “Bunk House 6,” is a 6-person outdoor folding tent with a backpack. The tent is composed of manmade textile materials. The tent has a net weight of 18.59 pounds, a floor area of 82 square feet, and a standing height of 78 inches. The tent is imported together with a backpack that houses the tent, rainfly, poles, and stakes. The backpack dimensions are 27 ½ inches in length by 17 inches in width by 7 ½ inches in height. SKU# TMESHSCSP25, described as an “Accessory Mesh Insert Sage Canyon Shelter Plus,” is a floorless outdoor mesh insert designed to be used with the Sage Canyon Shelter for bug protection. The mesh insert connects to the shelter by gear loops and features two zippered openings. The insert is composed of manmade textile materials. The mesh insert has a net weight of 4.52 pounds, a floor area of 90 square feet, and a standing height of 82 inches. The mesh insert is imported with a stuff sack that houses the mesh insert and stakes. The mesh insert does not come with poles. The stuff sack measures 7 inches in length by 7 inches in width by 22 inches in height. You state the pertinent manufacturing operations for the “Big House 4,” “Big House 6,” “Bunk House 4,” “Bunk House 6,” tents and “Sage Canyon Mesh Insert” are as follows: China: • Big House 4 and Big House 6 - o Backpack, rainfly, floor, and tent body, binding, loop, and corner fabric: 100 percent polyester fabric is woven, dyed, and coated with waterproof polyurethane (PU) on one side and shipped in rolls to Vietnam. o Zippers, sliders, eyelets, printed tape, aluminum poles, and aluminum stakes are produced and shipped to Vietnam. • Bunk House 4 and Bunk House 6 – o Floor, corner, binding, rainfly, and backpack fabric: 100 percent polyester fabric is woven, dyed, and coated with PU and shipped in rolls to Vietnam. o Body fabric: 100 percent polyester fabric is woven, dyed, and shipped in rolls to Vietnam. o Zippers, sliders, eyelets, printed tape, aluminum poles, and aluminum stakes are produced and shipped to Vietnam. • Sage Canyon Mesh Insert – o Bottom body fabric, stuff sack, and stake bag: 100 percent polyester fabric is woven, dyed, coated with polyurethane (PU), and shipped in rolls to Vietnam. o Zipper, slider, and aluminum stakes are produced and shipped to Vietnam. Korea: • Big House 4 and Big House 6 – o Door and Roof Mesh Fabric: 100 percent nylon fabric is woven, dyed and shipped in rolls to Vietnam. o Clip, hook, buckles, PVC square toggle, PVC O-ring, and lion lock are produced and shipped to Vietnam. • Bunk House 4 and Bunk House 6 – o Mesh Fabric: 100 percent nylon fabric is woven, dyed, and shipped in rolls to Vietnam. o Lite tent hook, PVC ball cap, buckle, PVC square toggle, and PVC O-ring, lion lock, are produced and shipped to Vietnam. • Sage Canyon Mesh Insert – o Mesh Fabric: 100 percent nylon fabric is woven, dyed, and shipped in rolls to Vietnam. o PVC square toggle and cord lock ellipse are produced and shipped to Vietnam. Taiwan: • Big House 4, Big House 6, Bunk House 4, and Bunk House 6 – o Seam tape is produced and shipped to Vietnam. The United Kingdom: • Big House 4, Big House 6, Bunk House 4, and Bunk House 6 – o Clam Cleat is produced and shipped to Vietnam. The United States: • Big House 4, Big House 6, Bunk House 4, and Bunk House 6 o Seam tape is produced and shipped to Vietnam. Vietnam: • Big House 4 and Big House 6 – o Webbing, Velcro, polyester string, thread, 10mm reflective, and E-band are produced. o Fabric is cut to shape and size. o Fabric is sewn and hemmed to create a tent, rainfly, and backpack. o The tent, rainfly, poles, and stakes are placed in the backpack. o The backpacks are packaged in cartons and shipped to the United States. • Bunk House 4 and Bunk House 6 – o Webbing, polyester string, thread, webbing, 10mm reflective, Velcro, and E-band are produced. o Fabric is cut to shape and size. o Fabric is sewn and hemmed to create a tent, rainfly, and backpack. o The tent, rainfly, poles, and stakes are placed in the backpack. o The backpacks are packaged in cartons and shipped to the United States. • Sage Canyon Mesh Insert o Webbing, polyester string, thread, and cord lock ellipse are produced. o Fabric is cut to shape and size. o Fabric is sewn and hemmed to create a mesh insert, stuff sack, and stake bag. o The stakes are placed into a stake bag. o All components are placed in the stuff sack. o The mesh inserts are packaged in cartons and shipped to the United States. ISSUES: What is the country of origin for the imported tents and mesh insert? CLASSIFICATION: You have suggested that the Big House 4, Big House 6, Bunk House 4, and Bunk House 6 style tent should be classified under subheading 6306.22, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tarpaulins, awnings and sunblinds; tents (including temporary canopies and similar articles); sails for boats, sailboards or landcraft; camping goods: Tents (including temporary canopies and similar articles): Of synthetic fibers.” We agree. You have also suggested that the Sage Canyon Mesh Insert should be classified under subheading, 6307.90.9891, HTSUS, which provides for “Other made up articles, including dress pattern: Other: Other: Other: Other: Other.” We agree. It is the opinion of this office that the tent and the backpack as well as the mesh insert and stuff sack together form a "composite good.” The classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Since no one heading in the tariff schedule covers the textile backpack and the tent or the textile stuff sack and the mesh insert in combination, GRI 1 cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite goods consisting of different materials

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 backpack and stuff sack have been determined to be a container in which the tent or mesh insert is packaged for retail sale and classified with the tent or mesh insert, the backpack and the stuffed sack fabrics are 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 pos