N355801

N355801 December 5, 2025 OT:RR:NC:N2:349 CATEGORY: Origin, Marking Xia Chen Nanjing Meihua Textile Co., Ltd. 12F, Hongyi Mansion, 459 Mid. Long Pan Road, QinHuai District Nanjing 211500 China RE: Country of origin and marking determination for mattress pads; 19 CFR 102.21(c)(5); last country in which an important assembly or manufacturing process occurred Dear Ms. Chen: This is in reply to your letter dated November 6, 2025, requesting a country of origin determination for a mattress pad, which will be imported into the United States. In lieu of a sample, photographs and a product description were provided. FACTS: SKU #11171 is a mattress pad designed to be placed on top of a mattress to provide additional comfort. It is comprised of an outer shell of 100 percent cotton plain woven fabric that is stuffed with white duck down. The shell fabric is bleached and dyed white. The mattress pad includes a self-fabric 20-inch-deep skirt with a fully elasticized edge. The mattress pad is available in the following sizes: Twin 39 x 75 inches, Twin XL 39 x 80 inches, Full 54 x 75 inches, Queen 60 x 80 inches, King 78 x 80 inches and California King 72 x 84 inches. It is packaged for retail sale in a reusable bag consisting of nonwoven fabric on the front, top, bottom and sides and polyvinyl chloride (PVC) on the back. There is a zipper closure and self-fabric handle on the top of the bag. The bag measures 19 × 22 × 3 inches. SKU #11180 is a mattress pad designed to be placed on top of a mattress to provide additional comfort. It is comprised of an outer shell of 100 percent cotton plain woven fabric that is stuffed with a polyester fiberfill. The shell fabric is bleached and dyed white. The mattress pad features a knife edge finish and is held in place with four seven-centimeter-wide elasticized woven bands of polyester and elastane sewn to each side of the four corners. The bands form straps that are secured to the mattress to prevent the pad from shifting or bunching. The mattress pad is available in the following sizes: Twin 39 x 75 inches, Twin XL 39 x 80 inches, Full 54 x 75 inches, Queen 60 x 80 inches, King 78 x 80 inches and California King 72 x 84 inches. It is packaged for retail sale in a reusable bag consisting of nonwoven fabric on the front, top, bottom and sides and polyvinyl chloride (PVC) on the back. There is a zipper closure and self-fabric handle on the top of the bag. The bag measures 19 × 22 × 3 inches. SKU #11221 is a mattress pad designed to be placed on top of a mattress to provide additional comfort. It is comprised of an outer shell of 100 percent cotton plain woven fabric that is stuffed with a white duck down. The shell fabric is bleached and dyed white. The mattress pad includes a 100 percent cotton jersey knit fabric skirt with a depth of 20 inches and a sewn-on three-centimeter-wide elasticized woven band edge of polyester and elastane. The mattress pad is available in the following sizes: Twin 39 x 75 inches, Twin XL 39 x 80 inches, Full 54 x 75 inches, Queen 60 x 80 inches, King 78 x 80 inches and California King 72 x 84 inches. It is packaged for retail sale in a reusable bag consisting of nonwoven fabric on the front, top, bottom and sides and polyvinyl chloride (PVC) on the back. There is a zipper closure and self-fabric handle on the top of the bag. The bag measures 19 × 22 × 3 inches. The manufacturing operations for the mattress pads, are as follows: PAKISTAN Greige cotton woven fabric for the shell is formed (SKU#s 11171 and 11180 and 11221). Elasticized cotton jersey narrow fabric is formed (SKU# 11221). The greige cotton fabric and narrow elasticized cotton jersey fabric are shipped in rolls to China. CHINA Cotton fabric is bleached, dyed and shrunk. Sewing thread is produced. Polyester staple fiber is manufactured (SKU# 11180). Duck down is harvested/sourced (SKU# 11171 and 11221). Elastic bands are formed (SKU#s 11171, 11180 and 11221). The fabric is cut and assembled by sewing into unfinished shell. The mattress pad is filled with Chinese-sourced white duck down (SKU#s 11171 and 11221) or polyester staple fiber (SKU# 11180), sewn closed and box quilted. Nonwoven fabric, PVC sheeting and zipper for bag is formed. Nonwoven fabric, PVC sheeting is cut and assembled by sewing with zipper to form bag. Face of bag is printed with “The Company Store” and logo. The mattress pad is packaged and shipped to the United States. ISSUE: What is country of origin and marking requirements 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:” The mattress pads are classified under subheadings 9404.90.81 and 9404.90.96, Harmonized Tariff Schedule of the United States (HTSUS). Prior to 2022, the corresponding HTSUS to subheading 9404.90.81 was subheading 9404.90.80 and subheading 9404.90.96 was 9404.90.95, HTSUS. Paragraph (e)(2) of Section 102.21 has not been updated with the current tariff subheadings. Therefore, we follow the rule corresponding to the prior classification, below. See New York Ruling Letter N338830. The reusable bag used as packaging for each mattress pad is classifiable under subheading 6307.90, HTSUS. Paragraph (e)(1) 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 6307. 90 The country of origin of a good classifiable under subheading 6307.90 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-making process” is defined in section 102.21(b)(2) as follows: A “fabric-making process” is any manufacturing operation that begins with polymers, fibers, filaments (including strips), yarns, twine, cordage, rope, or fabric strips and results in a textile fabric. Paragraph (e)(2) in pertinent part states, (2) For goods of HTSUS headings 6213 and 6214 and HTSUS subheadings 6117.10, 6302.22, 6302.29, 6302.53, 6302.59, 6302.93, 6302.99, 6303.92, 6303.99, 6304.19, 6304.93, 6

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:” The mattress pads are classified under subheadings 9404.90.81 and 9404.90.96, Harmonized Tariff Schedule of the United States (HTSUS). Prior to 2022, the corresponding HTSUS to subheading 9404.90.81 was subheading 9404.90.80 and subheading 9404.90.96 was 9404.90.95, HTSUS. Paragraph (e)(2) of Section 102.21 has not been updated with the current tariff subheadings. Theref