N358596

N358596 March 4, 2026 OT:RR:NC:N2:350 CATEGORY: Origin Emily Zhang 3H Medical (Thailand) Co., Ltd. 60 Moo 3, Hang Sung Subdistrict Nong Yai District Chon Buri 20190 Thailand RE: The country of origin of two bandage fabrics; 19 CFR 102.21(c)(2), tariff shift; 19 CFR 102.21(c)(4) Dear Ms. Zhang: In your letter dated February 6, 2026, you requested a tariff classification and country of origin ruling on two bandage fabrics. Samples of the two bandages were submitted and will be retained by our office. FACTS: In your original submission you submitted two samples of OK Tape brand cohesive bandages to our office, which are identified as “Woven cohesive bandage” and “Non-woven cohesive bandage.” These items will be referred to as the woven bandage and nonwoven bandage, respectively. Based on your submission and subsequent correspondence, we can ascertain that the woven bandage is of woven construction, composed of 95 percent cotton and 5 percent spandex, and that the nonwoven bandage is comprised of three layers constructed of a nonwoven layer of polypropylene (“PP”) fibers, a mesh layer of knitted polyester, and laid-in spandex yarns. The nonwoven bandage is composed of 62.5 percent (PP), 21 percent polyester and 16.5 percent spandex. The woven bandage has been coated with uncolored synthetic rubber and the nonwoven bandage has been coated with latex. The fabrics are cut to 2 inches in width by 14.8 feet in length and packaged for retail sale. You have presented four different prospective origin scenarios, one will apply to the woven bandage and three will apply to the nonwoven bandage. The manufacturing operations for the woven bandage are as follows: Scenario 1 China: Greige cotton fabric is woven, dyed and combined with elastic spandex yarns into a finished woven fabric. Finished fabric is exported in rolls in Thailand. Thailand: Fabric is coated with rubber, cured and dried. Fabric is cut to size and packaged for retail sale. Finished product is packaged in cartons and exported to the United States. The manufacturing operations for the nonwoven bandages are as follows: Scenario 2 China: Polypropylene nonwoven fabric, polyester mesh fabric, and the elastic spandex yarns are each formed and combined into finished bonded nonwoven fabric. Finished fabric is exported in rolls to Thailand. Thailand: Fabric is coated with latex, cured and dried. Fabric is cut to size and packaged for retail sale. Finished product is packaged in cartons and exported to the United States. Scenario 3 China: Polypropylene nonwoven fabric, polyester mesh fabric, and the elastic spandex yarns are each formed. Nonwoven fabric, mesh fabric in rolls and the elastic yarns spooled are exported to Thailand. Thailand Polypropylene nonwoven fabric, polyester mesh fabric, and the elastic spandex yarns are combined into a finished bonded nonwoven fabric. Fabric is coated with latex, cured and dried. Fabric is cut to size and packaged for retail sale. Finished product is packaged in cartons and exported to the United States. Scenario 4 China Polypropylene nonwoven fabric and polyester mesh fabric are each formed and bonded together. Elastic spandex yarns is formed. Bonded nonwoven fabric in rolls and elastic yarns spooled are exported to Thailand. Thailand Elastic spandex yarns are inserted into the two layer bonded nonwoven fabric into finished bonded nonwoven fabric. Fabric is coated with latex, cured and dried. Fabric is cut to size and packaged for retail sale. Finished product is packaged in cartons and exported to the United States. 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: HTSUS Tariff shift and/or other requirements 5906-5907 (1) Except for fabric of wool or of fine animal hair, a change from greige fabric of heading 5906 through 5907 to finished fabric of heading 5906 through 5907 by both dyeing and printing when accompanied by two or more of the following finishing operations: bleaching, shrinking, fulling, napping, decating, permanent stiffening, weighting, permanent embossing, or moireing; or, (2) If the country of origin cannot be determined under (1) above, a change to heading 5906 through 5907 from any other chapter, except from heading 5007, 5111 through 5113, 5208 through 5212, 5309 5602-5603 (1) Except for fabric of wool or of fine animal hair, a change from greige fabric of heading 5602 through 5603 to finished fabric of heading 5602 through 5603 by both dyeing and printing when accompanied by two or more of the following finishing operations: bleaching, shrinking, fulling, napping, decating, permanent stiffening, weighting, permanent embossing, or moireing; or (2) If the country of origin cannot be determined under (1) above, a change to heading 5602 through 5603 from any heading outside that group, provided that the change is the result of 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. The woven fabric, subject to origin in scenario 1 would be classifiable under heading 5906 of the Harmonized Tariff Schedule of the United States (“HTSUS”) as a rubberized textile fabric. In scenario 1, subject to paragraph (e)(1) above, you state the woven fabric is only dyed and no additional finishing p rocesses are performed, therefore paragraph (e)(1) is inapplicable. In scenario 1, subject to paragraph (e)(2) above, while there is a tariff shift to heading 5906, it is from the excepted headings of 5208 through 5212. Therefore, paragraph (c)(2) is inapplicable for determining the country of origin of the woven bandage in scenario 1. We proceed to paragraph (c)(3) for scenario 1. The nonwoven fabric, subject to origin in scenario 2, scenario 3, and scenario 4 would be classifiable under heading 5603, HTSUS, as a nonwoven fabric. In each of these cases, subject to paragraph (e)(1) above, no dyeing, printing or other finishing operations occurred, therefore, paragraph (e)(1) is inapplicable. In each of these cases, subject to paragraph (e)(2) above, the nonwoven fabric was formed in a single country, that is China, as per the terms of the tariff shift requirement, the country of origin of each nonwoven bandage in scena

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: HTSUS Tariff shift and/or other requirements 5906-5907 (1) Except for fabric of wool or of fine animal hair, a change from greige fabric of heading 5906 through 5907 to finished fabric of heading 5906 through 5907 by both dyeing and printing when accompanied by two or more of the following finishing operations: bleaching, shrinking,