Complex Textile Supply Chains and the Question of the Country of Origin

In Binding Ruling NY N303580, CBP determined El Salvador to be the country of origin of certain stuffed mattress covers. CBP has reviewed NY N303580 and has determined the ruling letter to be in error. It is now CBP's position that the country of origin of the stuffed mattress covers is either the United States, China, or El Salvador, depending on the style of mattress cover and respective fabric origin. CBP is proposing to modify the ruling and country of origin determination. Before taking this action CBP will consider public comments. Comments must be received on or before November 29, 2019.

The articles in are processed in more than one country, which complicated the country of origin determination.

Styles S-10 and 12

• Stuffed Fabric/Top and Border Knit/Cover are formed in the United States.
• Bottom Fabric is formed in the United States.
• Cutting, sewing, and assembly operations in El Salvador.

Style S-14

• Stuffed Fabric/Top Knit/Cover is formed in the United States.
• Border Fabric is formed in China.
• Bottom Fabric is formed in the United States.
• Cutting, sewing, and assembly operations in El Salvador.

Styles T-10 and 12

• Stuffed Fabric/Top Knit/Cover are formed in Mexico or China.
• Fabric is formed in China.
• Bottom Fabric is formed in China
• Cutting, sewing, and assembly operations in El Salvador.

CBP HOLDING:

• The country of origin for the S-10 and S-12 mattress covers is the United States.
• The country of origin for the S-14 mattress cover is El Salvador.
• The country of origin for the T-10 and T-1” mattress covers in which the component fabric is manufactured in China, is China.
• The country of origin for the T-1” and T-12 mattress covers in which the component fabrics are manufactured in China and Mexico, is El Salvador.

CBP's reasoning in this case can be viewed at CUSTOMS BULLETIN AND DECISIONS, VOL. 53, NO. 39, OCTOBER 30, 2019