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Court Classifies Entry Door Knobs Under Higher Duty Provision

Tuesday, September 26, 2017
Sandler, Travis & Rosenberg Trade Report

In Home Depot U.S.A. Inc. v U.S., the Court of International Trade classified key-operated locking hardware articles (entry door knobs) as door locks suitable for use with interior or exterior doors under HTSUS 8301.40.6030 (5.7 percent duty). Home Depot had argued for classification as metal mountings suitable for interior and exterior doors under HTSUS 8302.41.6045 (3.9 percent duty).

The subject goods are made of stainless steel, brass, or nickel and are packaged and sold with the following constituent parts: an exterior door knob with trim, an interior door knob with trim, a latch component, a flanged strike plate, keys, and installation hardware. Each knob has a locking feature: a thumbturn on the interior knob and a slot for a key on the exterior knob.

The CIT states that these articles are locks in that they are devices for securing a door consisting of a bolt or system of bolts propelled and withdrawn by a key, dial, etc. The fact that these particular locks incorporate door knobs while others do not, the court states, does not mean they are in character or function something other than described by HTSUS heading 8301.

The items are not classified as door knobs under heading 8302, the court adds, because they possess features (e.g., the locking mechanism) substantially in excess of door knobs. As a result, the items are not classifiable under more than one heading and are not composite goods subject to classification under GRI 3(b).

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