N359713

N359713 April 2, 2026 OT:RR:NC:N2:349 CATEGORY: Origin Matthew Bock Bock Trade Law 53 State Street, Suite 500 Boston, MA 02109 RE: Country of origin determination for duvet covers, pillow shams and quilts; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.21(c)(4); most important assembly or manufacturing process Dear Mr. Bock: This is in reply to your letter dated March 13, 2026, requesting a country of origin determination on behalf of your client, Sarita Handa Exports PVT. Ltd., for duvet cover sets and quilts, which will be imported into the United States. In lieu of samples, photographs were submitted with your request. FACTS: The subject merchandise consists of three duvet cover sets, consisting of a duvet cover and two shams, and two quilts. The Moonstone Duvet Cover Set consists of a duvet cover and two pillow shams. The front of the duvet cover and front and back of the pillow shams are composed of 69 percent polyester and 31 percent cotton jacquard woven fabric that has a textured marble appearance. The back of the duvet cover is composed of 60 percent cotton and 40 percent polyester woven fabric. The duvet cover and the pillow shams feature a knife edge finish and a zipper closure one inch from the bottom seam on the back to securely encase the duvet insert and the pillow. The duvet cover also includes self-fabric internal ties placed at each corner to secure the duvet in place. The duvet cover will be imported in sizes Full/Queen with standard sized pillow shams, measuring 20 × 28 inches, and King with 20 × 36-inch pillow shams. The set is imported by Macy’s Department Stores as part of their Hotel Luxury Bedding Collection. The Textured Chevron Duvet Cover Set consists of a duvet cover and two pillow shams. The front of the duvet cover and the front and back of the pillow shams are composed of 60 percent polyester and 40 percent cotton yarn-dyed jacquard woven fabric that forms an indistinct chevron pattern. The back of the duvet cover is composed of 100 percent cotton woven fabric. The duvet cover and pillow shams feature a self-flange with a knife edge finish and a zipper closure one inch from the bottom seam on the back to securely encase the duvet insert and the pillow. The duvet cover also includes 7 ½ inch long and 3/8-inch-wide self-fabric internal ties at each corner to secure the duvet in place. The duvet cover will be imported in sizes Full/Queen with standard pillow shams, measuring 20 × 28 inches, and King with 20 × 36-inch pillow shams. The set is imported by Macy’s Department Stores as part of their Hotel Luxury Bedding Collection. The Broken Stripe Duvet Cover Set consists of a duvet cover and two pillow shams. The front of the duvet cover and the front and back of the pillow shams are composed of 100 percent polyester yarn-dyed jacquard woven fabric that forms an indistinct stripe pattern of various widths. The back of the duvet cover is composed of 100 percent cotton woven fabric. The duvet cover and pillow shams feature a self-flange edge finish and a zipper closure 1 inch from the bottom seam of the back to securely encase the duvet insert and the pillow. The duvet cover also includes 7 ½ inch long and 3/8-inch-wide self-fabric internal ties at each corner to secure the duvet in place. The duvet cover will be imported in sizes Full/Queen with standard pillow shams measuring 20 × 28, and King with 20 × 36-inch pillow shams. The set is imported by Macy’s Department Stores as part of their Hotel Luxury Bedding Collection. The Velvet Lattice Quilt is a bed covering with a shell of 100 percent cotton fabric. The face of the shell is 100 percent cotton velvet woven fabric and the back fabric is 100 percent cotton sheeting. The quilt is stuffed with 100 percent polyester batting. A cross stitch pattern is stitched through the three layers forming a lattice pattern. The edges are finished with a double slub one inch width flange with a frayed edge or a knife edge finish. The quilt is imported in Twin, Full/Queen and King sizes. The quilt is imported by Pottery Barn. The Heirloom Scalloped Quilt is a bed covering with a shell of 100 percent cotton sheeting and 100 percent cotton batting filling. The quilt features a diamond quilting pattern in the center with a multi picture frame effect. The innermost frame is formed by three parallel rectilinear lines of quilting followed by a curvilinear intertwined pattern, a larger rectilinear frame consisting of seven parallel rectilinear lines of quilting and a larger curvilinear intertwined pattern. The edges are scalloped and finished with binding. The quilt is imported in Twin, Full/Queen and King sizes. The quilt is imported by Pottery Barn. The manufacturing operations for the duvet covers, shams and quilts are as follows: Bangladesh Polyester and cotton fibers are spun into yarns. All outer facing/shell fabrics, binding fabric and double slub fabric are woven. All griege woven fabric are exported to India. India Sewing thread, zippers, cotton nonwoven batting and polyester nonwoven batting are formed. Fabrics are subject to cleaning, bleaching, dyeing, rinsing, drying, heat steaming, shaping, pre-shrinking and final inspection. Fabrics are cut and assembled by sewing into duvet covers, pillows shams, and quilts. Quilts are quilted. Finished items are inspected, packaged, labeled and exported 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 (“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 (d) states, “Where a good classifiable in the Harmonized Tariff Schedule of the United States (HTSUS) as a set includes one or more components that are textile or apparel products and a single country of origin for all of the components of the set cannot be determined under paragraph (c) of this section, the country of origin of each component of the set that is a textile or apparel product shall be determined separately under paragraph (c) of this section.” We consider the “Moonstone Duvet Cover Set,” the “Textured Chevron Duvet Cover Set,” and the “Broken Stripe Duvet Cover Set” to be sets under the General Rules of Interpretation (GRI). 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. Proceeding to 19 CFR 102.21(c)(2), we note that the subject quilts are classified in subheading 9404.40, Harmonized Tariff Schedule of the United States (HTSUS). There is no current rule to determine the country of origin of a textile article classified under subheading 9404.40, HTSUS. Prior to 2022, the corresponding HTSUS classifications for subheading 9404.40, HTSUS, were subheadings 9404.90.80 and 9404.90.85, 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 classifications. Paragraph (c)(2) states, “Where the country of origin of a textile or apparel product cannot be

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 (d) states, “Where a good classifiable in the Harmonized Tariff Schedule of the United States (HTSUS) as a set includes one or more components that are textile or apparel products and a single country of origin for all of the components of the set cannot be determined under paragraph (c) of this section, the country of origin of each component of the set that is a textile or apparel product shall be determined separately under paragraph (c) of this section.” We consider the “Moonstone Duvet Cover Set,” the “Textured Chevron Duvet Cover Set,” and the “Broken Stripe Duvet Cover Set” to be sets under the General Rules of Interpretation (GRI). 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. Proceeding to 19 CFR 102.21(c)(2), we note that the subject quilts are classified in subheading 9404.40, Harmonized Tariff Schedule of the United States (HTSUS). Ther