Determining Country of Origin for Imported Textile and Apparel Products: What U.S. Importers Should Know

In the globalized world of textile and apparel production, it is common for garments to be assembled in multiple countries. However, for U.S. Customs and Border Protection (CBP), identifying the country of origin of imported goods especially textiles is critical for compliance with trade agreements, tariffs, labeling, and import restrictions.

If you’re an importer, getting this wrong can mean more than delays: it can result in detentions, penalties, or denied entry. Understanding how CBP determines origin and how a licensed customs broker can help is essential for smooth import operations.

The term country of origin means the country, territory, or insular possession in which a good originates or of which a good is the growth, product, or manufacture. Under 19 CFR §102.21, the country of origin of a textile or apparel product will be determined by sequential application of these general rules.

General Rules:

1 - Wholly Obtained or Produced

If a garment is made entirely in one country from fiber production to final assembly the country of origin is straightforward.

2 - Tariff shift and/or other requirements 

If components come from multiple countries, each foreign material incorporated in that good underwent an applicable change in tariff classification and/or met any other special requirement.

See more at: https://www.ecfr.gov/current/title-19/chapter-I/part-102/subpart-B/section-102.21

3 - Knit to Shape

• If the item is knit or crocheted directly into its final shape, the country where the knitting occurred is the origin.

• If the good was not knit to shape and the good was wholly assembled in a single country, the origin of the good is the country in which the good was wholly assembled. 

Knit to shape applies to any good of which 50 percent or more of the exterior surface area is formed by major parts (integral components) that have been knitted or crocheted directly to the shape used in the good.

The term “wholly assembled” when used with reference to a good means that all components, of which there must be at least two, preexisted in essentially the same condition as found in the finished good and were combined to form the finished good in a single country. Minor attachments/embellishments (for example, appliques, beads, spangles, embroidery, buttons) and minor subassemblies (for example, collars, cuffs, plackets, pockets), will not affect the status of a good as wholly assembled.  

4 - The most important process

If the origin still cannot be determined, CBP looks at where the most significant assembly or manufacturing operation occurred.

5 - The last country 

Where the country of origin of a textile or apparel product cannot be determined by above rules, it is the last country in which an important assembly or manufacturing process occurred. 

Special Rule for Sets:

If a good classifiable in the HTSUS as a set with multiple components from different countries, each textile component's origin of the set is determined separately under the same rules.

Examples in practice

Case 1: The subject merchandise consists of a fitted sheet designed to fit a massage table. The fitted sheet is constructed of 100% polyester woven fabric and has an elasticized edge. The elasticized edge is formed by inserting into the hem a narrow fabric, approximately 1.5 centimeters wide, made from rubber thread covered in polyester yarn.

The manufacturing operations for the fitted sheet are as follows:

China	Vietnam
Polyester fabric is woven.	Fabric is cut to size and shape.
Narrow elasticized fabric is formed.	Fabric components are hemmed with an elasticized edge.
Sewing thread is formed.	Completed fitted sheet is packaged and exported to the United States.
All materials are exported to Vietnam.

What is the country of origin of the subject merchandise?

As the fitted sheet is not wholly obtained or produced in a single country, rule no.1 is inapplicable. The fitted sheet is classified under 6302.32, Harmonized Tariff Schedule of the United States (HTSUS), rule no.2 shall apply as the country of origin of a good classifiable under heading 6301 through 6306 is the country in which the fabric comprising the good was formed by a fabric-making process.

Since the polyester woven fabric and the elasticized fabric are formed in a single country, country of origin is conferred in China.

Case 2: Style A is a women’s three-piece knit pajama set consisting of a tank-styled top, shorts and a gown. Each garment is constructed from 89 percent polyester and 11 percent elastane jersey knit fabric and none of the individual pieces will be available for separate purchase.

The applicable HTSUS subheading for

• the top: 6114.30.1020,

• the shorts: 6104.63.2030,

• the gown: 6110.30.3059,

The manufacturing operations are as follows:

China	Bangladesh
Fabric sourcing	Fabric cutting
Fabric producing	Sewing
Fabric printing	Labeling
	Packaging

What is the country of origin of the subject merchandise?

As the merchandise is not wholly obtained or produced in a single country, rule no.1 is inapplicable. Styles A have only one integral component and that is the knit fabric. Rule no.2 is not applicable since the garments, each having only one component or major part are not wholly assembled, nor does their production involve a fabric making process.

As styles A, are not knit to shape, and the good was wholly assembled in a single country, country of origin is conferred in Bangladesh.

Why a Customs Broker Is Important

CBP’s rules for determining country of origin for textiles and apparel are specific, enforceable, and complex. As an importer, your responsibility is to apply reasonable care and ensure accuracy in all declarations. Working with a qualified customs broker ensures that you are not alone in interpreting the rules especially when dealing with multi-country supply chains.

A licensed customs broker can:

• Analyze your production steps to determine legal origin

• Verify compliance with tariff shift

• Help prepare accurate entry documentation and labels

• Prevent costly misclassification, penalties, or shipment holds

Contact Spirit CHB Inc – A Trusted U.S. Customs Brokerage with 20+ Years of Experience

📧 Import@spiritchbinc.com📞 714-383-9973

📌 Disclaimer & Contact Information

This blog post is intended to provide general information. It does not constitute legal advice or a comprehensive compliance guide. For specific questions or assistance with your import transactions, please consult official U.S. Customs and Border Protection resources or reach out to a licensed customs broker.

For more information, visit the official CBP website: https://www.cbp.gov

Or contact Spirit CHB, Inc. – A Trusted Customs Brokerage📞 Phone: (714) 383-9973