Doorknobs With Keyed, Thumbturn Locks Classifiable as Doorknobs, CIT Says
Doorknobs with keyed, thumbturn locks are classifiable as knobs, not locks, in the tariff schedule, the Court of International Trade said in a March 26 decision that was publicly released April 2. After being directed by the U.S. Court of Appeals for the Federal Circuit to treat the door hardware as composite goods (see 1902190036), CIT found that the knobs give the hardware sets their essential character, classifying them in Harmonized Tariff Schedule of the United States (HTSUS) heading 8502.
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The trade court had originally found the door hardware sets, imported by Home Depot, classifiable as locks of HTSUS heading 8501, sustaining CBP’s classification of the merchandise on liquidation. The knobs, which have a keyhold and cylinder on one side and a thumbturn device on the other, are merely levers to operate the locks, CIT had said in its 2017 decision (see 1709220036). But on appeal, the Federal Circuit found the hardware sets had both knobs and locks, and were composite goods that should be classified according to General Rule of Interpretation 3(b).
GRI 3(b) provides that composite goods are classifiable “as if they consisted of the material or component which gives them their essential character.” CIT found commercial standards and marketing materials could go either way. In particular, the marketing materials variously identified the merchandise as a “knob,” “knobset,” “door knob,” “door knob with lock,” “entry knob,” “entry knobset,” “entry lock,” “keyed entry,” “lock” and “lockset.”
By weight and value, the lock components, which CIT defined as the keys, the lock cylinder and an exterior doorknob that has some of the features that are exclusive to the lock’s operation, make up a similar proportion of the hardware set as the doorknob components, defined as the interior knob assembly, latch assembly and strike plate, the trade court said.
But when comparing the weight and value of the door hardware sets imported by Home Depot with privacy and passage sets that are not keyed, the locking mechanisms do not make a big difference, CIT said. “The exterior knob and the key cylinder are the primary design differences of the subject merchandise compared to the design of the privacy device. The data indicate only small increases in weight and value and, therefore, show the high degree of commonality among the door devices,” it said.
“The court has not identified other cases in which quantitative data have been evaluated in this way, but here the court finds merit in such comparison,” CIT said. “Accordingly, the court determines that the similar weights and values of the various door devices provide some, albeit limited, support for the conclusion that the knob components comprise the product’s ‘essential character.’”
And the function of the knob component in particular gives the door hardware sets their essential character, CIT said. “The knob component can function without the lock component, but the lock component cannot function without the knob component,” it said. And while the door hardware sets provide some security, “its more significant function is to provide a means to grasp, open and close a door.” This is reinforced by a manufacturer’s recommendation that the sets are for interior use. This indicates that the key cylinder is an additional feature, but that the knob assemblies define the fundamental nature of the merchandise.
“A consumer does not purchase an entry device primarily, let alone predominantly, for its keyed lock component, but rather for its knob component that allows an individual to grasp, open and close a door,” CIT said. “A consumer whose predominant priority is security would purchase a different product such as a deadbolt.”
(Home Depot U.S. A., Inc. v. U.S., Slip Op. 20-40, dated 03/26/20, public version 04/02/20, Judge Reif)
(Attorneys: Randolph Rucker of Drinker Biddle for plaintiff The Home Depot U.S.A., Inc.; Edward Kenny for defendant U.S. government)