N364456

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364456 September 24, 2026 CLA-2-56:OT:RR:NC:N2:352 CATEGORY: Classification, Origin TARIFF NO.: 5607.49.3000 Ms. Karolína Rusová TIMM SLOVAKIA s.r.o. | TATRAROPES Nozdrkovce 3140/37 Trenín 911 04 Slovakia RE: The tariff classification and country of origin determination for an industrial rope; 19 CFR 102.21(c)(4) Dear Ms. Rusová: In your letter dated August 21, 2026, you requested a classification and country of origin determination for an industrial rope, which will be imported into the United States. A sample was submitted with your request and will be retained by this office for training purposes FACTS: The sample, SKU #8314038013, described as a “ICON Rope,” is a braided synthetic rope intended to be used for industrial lifting, towing, mooring, and other heavy-duty applications. The braided rope consists of 12 interwoven load-bearing strands of twisted continuous 100 percent High-Modulus Polyethylene (HMPE) filament yarns that are coated with polyurethane (PU). The rope is hollow and coreless. The braided rope has a diameter of 38 mm, a linear density of 7,070,000 decitex, and a total weight of 707 grams per meter. The rope features a small metal identification tag utilized solely for product traceability purposes. You state that the rope will be imported either in specified lengths with optional spliced ends or in continuous lengths on spools or drums, with the final delivery configuration depending on customer requirements. You state the manufacturing operations for the “ICON Rope” are as follows: CHINA or GERMANY: 100 percent HMPE raw pellet resin is produced and shipped to China. CHINA: 100 percent HMPE filament yarn is extruded and wound onto paper tubes, packaged in cartons boxes, palletized, and shipped to Slovakia (subheading 5402.49). SLOVAKIA: Load-bearing strands are assembled based on rope specifications and impregnated with polyurethane. Twelve strands are braided into a rope, with six strands oriented clockwise and six counterclockwise. The finished braided rope is dried, stabilized, wound onto a spool or drum, cut to the required length according to customer requirements, inspected, and exported to the United States. ISSUE: What is the classification and country of origin of the subject merchandise? CLASSIFICATION: Based on the provided information, the applicable subheading for the “ICON Rope” will be 5607.49.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Twine, cordage, ropes and cables, whether or not plaited or braided: Of polyethylene or polypropylene: Other: Other.” The general rate of duty will be 3.6 percent ad valorem. 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 5607 If the good is of continuous filaments, including strips, a change of those filaments, including strips, to heading 5607 from any other heading, except from heading 5001 through 5007, 5401 through 5406, and 5501 through 5511, and provided that the change is the result of an extrusion process; or If the good is of staple fibers, a change of those fibers to heading 5607 from any other heading, except from heading 5106 through 5110, 5204 through 5207, 5306 through 5308, and 5508 through 5511, and provided that the change is the result of a spinning process. The “ICON Rope” does not contain staple fibers. However, since the “ICON Rope” is composed of 100 percent HMPE filament yarns which are classified within heading 5402, HTSUS, the finished “ICON Rope” does not meet the terms of the tariff shift and thus Section 102.21(c)(2) is inapplicable. Section 102.21(c)(3) states, Where the country of origin of a textile or apparel product cannot be determined under paragraph (c)(1) or (2) of this section: (i) If the good was knit to shape, the country of origin of the good is the single country, territory, or insular possession in which the good was knit; or (ii) Except for goods of heading 5609, 5807, 5811, 6213, 6214, 6301 through 6306, and 6308, and subheadings 6209.20.5040, 6307.10, 6307.90, and 9404.90, if the good was not knit to shape and the good was wholly assembled in a single country, territory, or insular possession, the country of origin of the good is the country, territory, or insular possession in which the good was wholly assembled. As the subject merchandise is not knit to shape, 19 CFR 102.21(c)(3)(i) is inapplicable. Although twisting of the yarns is considered an assembly operation, braiding is viewed as a manufacturing operation. Therefore, since the subject merchandise is not wholly assembled in a single country, 19 CFR 102.21(c)(3)(ii) is inappropriate. See NY Ruling C83113 and HQ 555594. Paragraph (c)(4) states, “Where the country of origin of a textile or apparel product cannot be determined under paragraph (c) (1), (2) or (3) of this section, the country of origin of the good is the single country, territory, or insular possession in which the most important assembly or manufacturing process occurred.” Section 334 of the URAA, (19 U.S.C. 3592(b)(1)) states, in pertinent part, that a textile or apparel product originates in a country and is the growth, product, or manufacture of that country if: (B) the product is a yarn, thread, twine, cordage, rope, cable, or braiding and (i) the constituent staple fibers are spun in that country, territory, or possession, or (ii) the continuous filament is extruded in that country, territory, or possession. These rules explicitly state the most important manufacturing process occurs where the filament is extruded. As the filament was extruded in China, the country of origin for the subject merchandise is China. See ruling NY D84393 and HQ 561092. HOLDING: The applicable subheading for the “ICON Rope” will be 5607.49.3000, HTSUS, and the country of origin is China pursuant of 102.21(c)(4). The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The t

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 5607 If the good is of continuous filaments, including strips, a change of those filaments, including strips, to heading 5607 from any o