The country of origin of a doorknob with an integral keyed lock

N351368 August 14, 2025 OT:RR:NC:N5:121 CATEGORY: Origin Kristina Barry GDLSK LLP 599 Lexington Avenue, FL 36 New York, NY 10022 RE: The country of origin of a doorknob with an integral keyed lock Dear Ms. Barry: In your letter dated July 15, 2025, you requested a country of origin ruling on a doorknob with an integral keyed lock on behalf of Lewis Hyman, Inc. The merchandise under consideration is identified as a Mechanical Entry Door Lock, item number 1731601. It consists of the internal and external doorknob assemblies, lock cylinder, strike plate, latch, keys, and hardware. The article is used for entry doors such as front entry doors, garage doors and kitchen doors. Your proposed manufacturing plan includes manufacturing the internal and external doorknob assemblies, the cylinder cover, and the strike plate in China. Those components would then be exported to Vietnam and assembled with the Vietnamese-origin cylinder plug, housing, keys, latch assembly, screws, and packaging. The completed article would be packaged in Vietnam and exported to the United States. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character and use has been produced. No one factor is decisive. Assembly operations that are minimal will generally not result in a substantial transformation. Courts have also considered “the ‘essence’ of a completed article to determine whether an imported article has undergone a change in character as a result of post importation processing.” Id. (citing Uniden America Corp. v. United States, 120 F. Supp. 2d 1091, 1095-1098 (Ct. Int’l Trade 2000) and Uniroyal, Inc., 542 F. Supp. 1030). In Uniroyal, Inc., 542 F. Supp. at 1029-1030, the court determined that the shoe upper was “the very essence of the completed shoe” and that the attachment of the imported shoe uppers to an outer sole in the United States was a “minor manufacturing or combining process which leaves the identity of the upper intact,” therefore, the shoe upper was not substantially transformed in the United States. The Court of International Trade determined that a doorknob with an integral keyed lock, such as this subject article, is properly classified as a composite good within the meaning of HTSUS GRI 3(b). The Court determined that the knob component (rather than the lock component) provides the essential character because “the primary function of a keyed entry device is to grasp, open and close the door, a function provided by the knob component.” Therefore, this subject mechanical entry door lock is classified in heading 8302 as a fitting suitable for a door. See Home Depot United States Inc. v. United States, 435 F.3d 1311 (2020). For similar reasons, we find that the internal and external doorknobs impart the essence to this subject good. The doorknob assemblies produced in China are not substantially changed by either the addition of the Vietnamese components that primarily provide the locking capability or the minor assembly operations performed in Vietnam. The Chinese produced internal and external doorknobs provide the essential operational elements for the doorknob with an integral keyed lock to work. In view of these facts, the country of origin of the Mechanical Entry Door Lock, item number 1731601, would be China. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division