Background

In Home Depot U.S.A. Inc. v U.S., the Court of International Trade has classified keyed entry devices used typically on exterior doors of residential structures as doorknobs under HTSUS 8302.41.6045 (3.9 percent duty) rather than as door locks under HTSUS 8301.40.6030 (5.7 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 knob assembly, an interior knob assembly, a latch assembly, a flanged strike plate, a key cylinder, two keys on a ring, and mounting hardware. Each knob has a locking feature: a thumb turn on the interior knob and a slot for a key on the exterior knob.

The CIT initially ruled that these products are locks, stating that while they incorporate doorknobs this does not mean they are in character or function something other than described by HTSUS heading 8301. However, the Court of Appeals for the Federal Circuit vacated that decision and held that the products are composite goods under GRI 3(b) because they include both a lock component (heading 8301) and a doorknob component (heading 8302).

On remand, the CIT concluded that the essential character of the products is conveyed by its doorknob component rather than its lock component. The CIT explained that the primary function of a keyed entry device is to grasp, open, and close a door, with the provision of security a secondary function. A consumer primarily concerned about security, the CIT said, would purchase a different product, such as a deadbolt.

The CAFC also examined commercial standards, marketing materials, and quantitative data in its attempt to assess the product’s essential character. However, the court determined that (1) neither the product descriptions contained in the relevant ANSI standards nor the presence or absence of a dead locking latch bolt weighs in favor of classifying the products under one tariff provision or the other, (2) marketing materials such as descriptions in product web pages, labels in physical product packaging, and retailer buying guides do not weigh in favor of classification one way or the other, and (3) quantitative data such as the weight, value, and visible surface area of the subcomponents listed above provide limited support for the conclusion that the doorknob component imparts the product’s essential character.

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