N357087

N357087 January 6, 2026 OT:RR:NC:CEE004:N2:349 CATEGORY: Origin, Marking Mr. Jeff Victoria Macy's Merchandising Group 151 W. 34th St. New York, NY 10001 RE: Country of origin determination for decorative pillows; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.21(c)(5); last country where an important assembly or manufacturing process occurred; 19 CFR 102.13; De Minimis Dear Mr. Victoria: This is in reply to your letter dated December 16, 2025, requesting a country of origin determination for decorative pillows, which will be imported into the United States. Photographs were submitted in lieu of samples. FACTS: Style 100227449DP is a 12 x 16 inch decorative pillow consisting of a pillow insert and removable cover. The cover is made of 100 percent cotton woven fabric. The insert is made of 55 percent cotton and 45 percent polyester woven fabric filled with polyester staple fiber. The pillow features a 1 ½ inch self-flange, double scalloped embroidery on scalloped edges and an envelope closure on the back. Style 100212221DP is a 14 × 24 inch decorative pillow consisting of a pillow insert and removable cover. The cover is made of 100 percent cotton woven fabric that is embroidered on the face. The insert is made of 55 percent cotton and 45 percent polyester woven fabric filled with polyester staple fiber. The pillow features a knife edge on all sides and an invisible zipper one inch from the bottom seam. Style 10016646600 is a 20 × 20 inch decorative pillow consisting of a pillow insert and removable cover. The cover is made of 100 percent cotton woven fabric that is embroidered on the face. The insert is made of 55 percent cotton and 45 percent polyester woven fabric filled with polyester staple fiber. The pillow features 1/8-inch self-corded piping on all four sides and an invisible zipper one inch from the bottom seam. The manufacturing operations for the decorative pillows are as follows: PAKISTAN: 100 percent cotton greige fabric for cover is woven. 100 percent cotton greige fabric is exported to China. CHINA: 55 percent cotton, 45 percent polyester fabric for pillow insert is woven. 100 percent polyester staple fiber is manufactured. Zippers are manufactured. (Styles 100212221DP and 10016646600) Piping cord and piping (from piping cord and 100 percent cotton greige fabric) is formed. (Style 10016646600) Pillow cover fabric undergoes bleaching, dyeing, desizing, singeing, mercerizing, washing, mechanical and chemical finishing and shrinking. Pillow cover is embroidered. Pillow insert fabric is cut, assembled by sewing, filled to create pillow insert and sewn closed. Pillow cover is cut and assembled by sewing. The pillow is inserted into the cover, packaged and exported to the United States. ISSUE: What is the country of origin of the subject merchandise for marking purposes? 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:” 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 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 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, 6304.99, 9404.90.85 and 9404.90.95, except for goods classified under those headings or subheadings as of cotton or of wool or consisting of fiber blends containing 16 percent or more by weight of cotton: (i) The country of origin of the good is the country, territory, or insular possession in which the fabric comprising the good was both dyed and printed when accompanied by two or more of the following finishing operations: bleaching, shrinking, fulling, napping, decating, permanent stiffening, weighting, permanent embossing, or moireing; The pillows are classifiable in subheading 9404.90.10, Harmonized Tariff Schedule of the United States (HTSUS), and are not subject to paragraph (e)(2). It would initially appear that paragraph (c)(2) does not apply as the fabrics comprising the pillows are formed in two countries; the fabric forming the covers is formed in Pakistan and the fabric comprising the pillow inserts is formed in China. However, with respect to Styles 100212221DP and 10016646600, the fabric comprising the pillow inserts is disregarded in accordance with Section 102.13, the De Minimis rule. Section 102.21(c), "General Rules," inter alia, state the requirements or conditions of Sections 102.12 through 102.19, where appropriate, are applicable when determining origin under Section 102.21(c)(1) through (5) Section 102.13 "De Minimis," states the following, in pertinent part: (c) Foreign components or materials that do not undergo the applicable change in tariff classification set out in Section 102.21 or satisfy the other applicable requirements of that section when incorporated into a textile or apparel product covered by that Section shall be disregarded in determining the country of origin of the good if the total weight of those components or materials is not more than 7 percent of the total weight of the good. You have indicated the fabric forming the shell of the pillow insert constitutes 9.65 percent of the weight of the pillow for style 100227449DP, 6.25 percent for style 100212221DP and 5.63 percent for style 10016646600; therefore, as this fabric is less than 7 percent of the total weight of styles 100212221DP and 10016646600, it is disregarded in determining the country of origin of these styles. As the remaining fabric forming the pillows, styles 100212221DP and 10016646600, is formed by the fabric-making process in a single country, that is Pakistan, as per the terms of the tariff shift requirement, country of origin is conferred in P

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:” 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 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 class