N358443

N358443 February 13, 2026 OT:RR:NC:N3:351 CATEGORY: Origin Ms. Jo-Anne Daniels Jo-Anne Daniels DBA Trade Resources & Associates 230-B Tyson Avenue Paris, TN 38242 RE: Country of origin determination for a playmat, storage bin, and swaddling wraps with drawstring bag; 19 CFR 102.21(c)(2) and 19 CFR 102.21(c)(4) Dear Ms. Daniels: In your letter, dated February 2, 2026, you requested a country of origin determination on behalf of your client, Crane USA, Inc, for three items. Samples of the product were provided to this office and will be retained for training purposes. Sample 1, Item #BC-100PM, described as a “Parker Quilted Play Mat,” is a quilted mat intended to be placed on the floor or other surface for a baby to lay on. The mat consists of three layers: a single layer of 100 percent polyester batting sheet is sandwiched between two layers of 100 percent cotton woven sateen fabric. The three layers are quilted together. The round shaped mat measures 40 inches in diameter and is finished with tassels along the perimeter. The mat is imported without toys such as a mirror, rattle, crinkle paper toys, or a squeaker. You state the item is available in five additional style numbers, each with its own SKU number and style name: BC-110PM, “Ezra Quilted Playmat”; BC-120PM, “Kendi Quilted Play Mat”; BC-130PM, “Caspian Quilted Play Mat”; BC180PM, “Willow Quilted Play Mat”; and BC-190PM-2, “Charlie Farmhouse Quilted Play Mat.” Sample 2, Item #BC-120SB-2, described as a “Kendi Safari Animal Nursery Storage Carry Bag,” is a textile storage bin designed and intended to store items. The open top, round-shaped bin is constructed of 100 percent cotton woven, printed canvas fabric. The top rim of the bin is folded over and finished with a 1 ¼ inch wide 100 percent cotton woven binding. The unlined storage bin measures 13 inches in diameter by 12 inches in height and features two rectangular slit handles. You state the item is available in two additional styles, each with its own SKU number and style name: BC-110SB, “Ezra Woodland Animal Nursery Storage Carry Bag,” and BC-180SB-1, “Willow Boho Batik Nursery Storage Carry Bag.” Sample 3, Item #BC-100SWS, described as a “Parker 2-Piece Swaddle Wraps,” is a set of two multipurpose textile items packaged inside a self-fabric textile drawstring bag. Both wraps are designed to be used as an on-the-go changing pad, to wrap and snuggle a baby, while nursing, or to provide shade in a stroller. Each multi-use item is composed of two layers of lightweight 100 percent cotton woven muslin, printed fabric. Each item measures 47 x 47 inches and is hemmed on all four sides. The swaddle blankets are washable and reusable. Both wraps will be packaged inside a self-fabric bag. The square-shaped bag measures 10 ½ by 10 ½ inches and is sewn on three sides. The bag is unlined with a drawstring-type closure using narrow woven fabric (instead of a drawstring) to cinch the bag closed. You state the item is available in ten additional styles, each with its own SKU number and style name: BC-100SWS-2, “Parker 2pc Butterfly/Rainbow Swaddle Set”; BC-110SWS, “Ezra 2pc Swaddle Wraps (Copper Dash & Ezra Print)”; BC-120SWS, “Kendi 2pc Swaddle Wraps”; BC-130SWS, “Caspian 2pc Swaddle Wraps”; BC-190SWS-1, “Charlie Tractor/Dot 2pc Swaddle Set”; BC-190SWS-2, “Charlie Goose/Check 2pc Set”; BC-160SWS-1, “Cove 3pc Beach Life Swaddle”; BC-160SWS-2,” Cove 3pc Sea Life Swaddle”; BC-150SW-1, “Avery Bunny Swaddle Blanket”; BC-150SW-2, “Avery Poppy Swaddle Blanket.” You state the manufacturing operations for the playmat, storage bin, swaddle wraps, and drawstring bag are as follows: Uzbekistan: Playmat: Cotton is grown and yarn is spun. 100 percent cotton griege top layer fabric is woven. 100 percent cotton griege bottom layer is woven. Griege top layer fabric undergoes pre-treatment processes including, singeing, desizing, scouring, bleaching, and mercerization, drying, printing, heat curing or steaming, washing, final drying, and finished through stentering drying, softening, and shrinkage control prior to final inspection. Griege bottom layer fabric undergoes pre-treatment processes including, singeing, desizing, scouring, bleaching, and mercerization, drying, solid dying, heat curing or steaming, washing, final drying, and finished through stentering drying, softening, and shrinkage control prior to final inspection. 100 percent polyester thread is produced Polyester thread on cones and finished cotton printed and dyed fabric on rolls are shipped to India. Storage Bin: Cotton is grown and yarn is spun. 100 percent cotton griege fabric is woven. Griege fabric undergoes pre-treatment processes including, singeing, desizing, scouring, bleaching, and mercerization, drying, printing, heat curing or steaming, washing, final drying and finished through stentering drying, softening, and shrinkage control prior to final inspection. 100 percent polyester thread is produced. Polyester thread on cones and finished cotton printed fabric on rolls are shipped to India. Swaddle Wraps and Drawstring bag: Cotton is grown and yarn is spun. 100 percent cotton greige muslin fabric is woven Greige muslin fabric undergoes pre-treatment processes including singeing, desizing, scouring, bleaching, and mercerization, drying and preparing for two-layer formation. Once aligned and tacked, the fabric is either engraved with a design or digitally printed, then heat-cured, washed, and finished through stentering drying, softening, and shrinkage control prior to final inspection. 100 percent polyester thread is produced. Polyester thread on cones and finished cotton printed fabric on rolls are shipped to India. India: Playmat: 100 percent cotton tassels are produced. 100 percent polyester batting sheet is produced. Fabric and tassels are cut. Fabric and batting sheet are quilted together. Tassels are sewn around the edges to finish the playmat. Completed playmat is inspected, attached with sewing label, hangtag, and packaged for export to the United States. Storage Bin: 100 percent cotton binding tape is woven. Fabric and binding tape are cut and sewn to create a storage bin. The storage bin is packaged and shipped to the United States. Swaddle Wraps and Drawstring Bag: Fabric is cut and sewn to create a wrap and drawstring bag. Two wraps are packaged in a drawstring bag and shipped 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 (codified at 19 U.S.C. 3592), enacted on December 8, 1994, provided rules of origin for textiles and apparel entered, or withdrawn from warehouse for consumption, on and after July 1, 1996. Section 102.21, Customs Regulations (19 C.F.R. 102.21), published September 5, 1995, in the Federal Register, implements Section 334 (60 FR 46188). Section 334 of the URAA was amended by section 405 of the Trade and Development Act of 2000, enacted on May 18, 2000, and accordingly, section 102.21 was amended (68 Fed. Reg. 8711). Thus, 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. 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, spec

Section 334 of the Uruguay Round Agreements Act (codified at 19 U.S.C. 3592), enacted on December 8, 1994, provided rules of origin for textiles and apparel entered, or withdrawn from warehouse for consumption, on and after July 1, 1996. Section 102.21, Customs Regulations (19 C.F.R. 102.21), published September 5, 1995, in the Federal Register, implements Section 334 (60 FR 46188). Section 334 of the URAA was amended by section 405 of the Trade and Development Act of 2000, enacted on May 18, 2000, and accordingly, section 102.21 was amended (68 Fed. Reg. 8711). Thus, 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. 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)(1) provides the rules used to determine the country of origin of a textile or apparel product under paragraph (c)(2) of this section. These rules are dependent on the classification of the good. The playmat, storage bin, swaddle wraps, and drawstring bag are classified under subheading 6307.90.9891, Harmonized Tariff Schedule of the United States (HTSUS). 

Paragraph (e) in pertinent part states, The following rul