Doorknobs With Thumbturn Locks Classifiable as Locks in Tariff Schedule, CIT Says
Door hardware with knobs that incorporate locks are classifiable as locks in the tariff schedule, the Court of International Trade said in a decision issued Sept. 21. The importer of the hardware, Home Depot, had argued it was classifiable as mountings and fittings for doors, and dutiable at a lower rate. CIT held that, though the hardware includes doorknobs that would be classified as mountings and fittings if imported alone, here the doorknobs acted as levers for a lock.
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The hardware sets imported by Home Depot included exterior and interior door knobs, a latch, a strike plate, keys and installation hardware. Each knob had a locking feature, with a thumbturn on the interior knob and a slot for a key on the exterior. CBP liquidated the merchandise in subheading 8301.40.6030 as “locks (key, combination or electrically operated), dutiable at 5.7%. Home Depot protested, arguing for classification in subheading 8302.41.6045, dutiable at 3.9%.
Heading 8302 does cover “handles and knobs for doors, including those for locks and latches,” CIT said. But knobs can also be parts of a lock, it said. Home Depot certified the hardware to industry specifications that describe an “entry lock” as “operated by lever from either side except when [the] outside lever is locked by turn button or [another] locking device inside.” The standard “describes the subject articles’ interior (inside) and exterior (outside) knobs (levers) as parts of a lock,” CIT said. Home Depot also described the hardware sets as “locks” on its website, the court said.
As locks, the hardware sets are classifiable in heading 8301, CIT said. “In sum, a lock is a multi-component device, of which one component is a lever. In some types of locks, the lever is a door knob,” it said. “The fact that these particular locks incorporate door knobs, whereas some locks do not, does not mean that the subject articles ‘are in character or function something other than as described by’ heading 8301,” CIT said. “Of course, door knobs are not always parts of “key, combination or electrically operated” locks. And, when they are not, they may be properly classified under heading 8302.”
For example, “heading 8302 accurately describes the exterior and interior knob components” of Home Depot’s door hardware kits, CIT said. Also, though privacy door knobs meet CIT’s definition of a lock, as a multicomponent device “including a bolt and a mechanism for propelling and withdrawing the bolt,” CIT said “heading 8301 is expressly limited to ‘key, combination or electrically operated’ articles. Privacy door knobs, even if locks, are not ‘key, combination or electrically operated,’” and are not classifiable as locks of heading 8301.
(Home Depot U.S.A. v. U.S., Slip Op. 17-129, CIT # 14-00061, dated 09/21/17, Judge Goldberg)
(Attorneys: William Rucker of Drinker Biddle for plaintiff Home Depot U.S.A.; Amy Rubin for defendant U.S. government)