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October 2024, question 62

Entry / Entry Summary · Rules of origin and trade programs

Cotton seeds from the cotton species Gossypium barbadense are imported into the U.S. from Egypt. Plants of the species Gossypium barbadense grow the cotton commonly known as Egyptian Cotton. The cotton seeds are planted in Mississippi and then the cotton is harvested. The harvested cotton is turned into 100% cotton thread in the Dominican Republic. The 100% cotton thread is woven into cotton fabric suitable for making shirts and this fabric is cut into pieces in Vietnam. The cut pieces are sewn into shirts in Israel using 100% cotton thread and exported to the United States. What is the country of origin of the shirts?

  1. Egypt
  2. United States
  3. Vietnam
  4. Israel
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CBP's answer: D. D: Israel

For goods exported from Israel, 102.22 decides whether a textile or apparel product is a product of Israel, and it is when it last underwent a substantial transformation there. Sewing all the cut pieces into completed shirts is such an operation under 102.22(c)(1)(v), so the shirts are products of Israel (D) even though the cotton, thread, fabric and cutting came from other countries.

will be a product of Israel if it last underwent a substantial transformation in Israel 19 CFR 102.22(a)
Substantial assembly by sewing and/or tailoring of all cut pieces of apparel articles which have been cut from fabric in another foreign territory or country 19 CFR 102.22(c)(1)(v)

Search for: product of Israel textile apparel last underwent substantial transformation

CBP's key cites: 19 CFR 102.21(a); 19 CFR 102.22(a); 19 CFR 102.22(b)(1)(i); 19 CFR 102.22(c)(1)(v); 19 CFR 102.22(d)

Question and key from CBP's October 2024 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).