The country of origin of a single and a double cylinder deadbolt lock

N357158 January 13, 2026 OT:RR:NC:N5:121 CATEGORY: Origin George Tuttle, III Tuttle Law Offices 3950 Civic Center Dr, Ste 102 San Rafael, CA 94903 RE: The country of origin of a single and a double cylinder deadbolt lock Dear Mr. Tuttle: In your letter dated December 17, 2025, you requested a country of origin ruling of a single and a double cylinder deadbolt lock on behalf of Taiwan Fu Hsing Industrial Co., Ltd. The first article under consideration is identified as a Single Cylinder Deadbolt Lock. It consists of five main components: an external key assembly, a latch assembly, a strike plate, an internal assembly, and an external assembly that are packaged together for sale and ready for installation. The function of this item is to lock and secure a door. It has a keyed lock on the outside of the door and a thumb-turn lever on the inside of the door. The second article under consideration is identified as a Double Cylinder Deadbolt Lock. It consists of six main components: an external key assembly, an internal key assembly, a latch assembly, a strike plate, an internal assembly, and an external assembly that are packaged together for sale and ready for installation. The function of this item is to lock and secure a door. It has a keyed lock on both the outside and the inside of the door. You have proposed a manufacturing scenario in which the keys, strike plate, cylinder plug, cylinder housing, top pin spring, bottom pins, top pins, and cylinder housing pins will be manufactured in Taiwan. The Single Cylinder Lock includes a thumb-turn, which is also manufactured in Taiwan. The external key assembly for the Single Cylinder Lock and both the external and internal key assemblies for the Double Cylinder Lock are assembled in Taiwan. Those components would then be exported to Thailand and/or China and assembled with the latch assembly and the trim for the internal and external subassemblies of Thailand or Chinese origin. The completed Single- and Double- Cylinder Deadbolt Locks will be packaged in Thailand and/or China 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 this instance, it is this office’s opinion that the keys, strike plate, cylinder plug, cylinder housing, thumb-turn (for the single cylinder deadbolt), top pin spring, bottom pins, top pins, and cylinder housing pins which are to be manufactured in Taiwan, and the appropriate internal and external key assemblies that are assembled in Taiwan provide the essence of the Single- and Double- Cylinder Deadbolt Locks. These items are not substantially changed by the addition of the latch assembly and trim of Thailand and/or Chinese origin. The Taiwan-produced keys, strike plate, cylinder plug, cylinder housing, thumb-turn, top pin spring, bottom pins, top pins, cylinder housing pins, and the appropriate external and internal key assemblies would provide the essential operational elements for the Single- and Double- Cylinder Deadbolt Locks to work. In view of these facts, the country of origin of the Single Cylinder Deadbolt Lock and the Double Cylinder Deadbolt Lock would be Taiwan. 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division