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RE: The tariff classification and country of origin determination for an industrial rope; 19 CFR 102.21(c)(4)
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 N364457 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 #8714038009, described as a “ICON HD 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 three layers: a hollow High-Modulus Polyethylene (HMPE) load-bearing core; a protective mid-layer composed of a 100 percent polypropylene (PP) non-woven sand-filter fabric laminated to a plastic film, which is wraps around the core to keep dirt and solid particles out; and an outer 100 percent HMPE braided protective cover. The core is composed of 12 interwoven load-bearing strands of twisted 100 percent HMPE continuous filament yarns coated with polyurethane (PU). The braided protective cover is composed of 32-strands of 100 percent HMPE filament yarns. The finished braided rope has a diameter of 38 mm, a linear density of 10,722,000 decitex, and a total weight of 1005 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 in specified lengths with optional spliced ends or in continuous lengths either on reels or drums with the final delivery configuration depending on customer requirements. You state the manufacturing operations for the “ICON HD 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 into carton boxes, palletized, and shipped to Slovakia (subheading 5402.49). BELGIUM: Plastic adhesive film is produced and shipped to Slovakia. ROMANIA: 100 percent polypropylene nonwoven staple fiber fabric is produced, rolled and shipped to Slovakia. SLOVAKIA: Load-bearing strands are assembled based on rope specifications and impregnated. Twelve strands are braided into a balanced load-bearing core, with six strands oriented clockwise and six counterclockwise. The completed 12-strand load-bearing core is dried and stabilized. The 100 percent polypropylene (PP) non-woven sand-filter fabric is laminated to a plastic film. The HMPE yarns intended for the 32-strand outer protective cover are impregnated. The laminated PP non-woven sand-filter fabric is wrapped around the inner core. The 32-strand HMPE protective cover is braided over the load-bearing core and sand-filter layer. The finished rope is cut to the required length according to customer specification and wound onto reels or drums, with or without splices end terminations. The finished rope is inspected according to manufacturing and technical specifications. The finished rope is packaged onto reels or drums, placed on pallets without cartons, and exported to the United States. ISSUE: What is the tariff classification and country of origin of the subject merchandise? CLASSIFICATION: Based on the provided information, the applicable subheading for the “ICON HD 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 (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) 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 HD Rope” is composed of 100 percent HMPE filament yarns in both the load-bearing core and the outer protective cover which are classified within heading 5402, HTSUS. Thus, the finished “ICON HD Rope” does not meet the terms of the tariff shift and 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
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) 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