INFO-2:OT:RR:NC:N1:121
Yesenia Gallegos
Allegion
Trade Compliance Manager
11819 North Pennsylvania S Street
Carmel, IN 46032
RE: The tariff classification of keyed entry door devices from Mexico
Dear Ms. Gallegos:
In your letter dated July 13, 2020, you requested a tariff classification ruling.
The articles under consideration are identified as keyed entry door devices, style numbers W511 and A53. Style W511 is made predominately of steel and zinc. It has a push button on the inside knob/lever (or interior) and a slot for a key on the outside knob/lever (or exterior). The interior push button feature consists of a button on the inside that locks the outside lever/knob until it is unlocked by a key or by rotating the inside handle. Style W511 is packaged and sold unassembled with the following constituent parts: an exterior door knob or lever assembly, an interior door knob or lever assembly, a latch bolt assembly, a chassis, a keyed interchangeable cylinder, keys, a strike plate, and mounting hardware. This style does not include a deadbolt.
Style A53 is made predominately of steel and zinc. It is a keyed entry device with keyed cylinders. This style can be customized to include one of four knob designs or one lever design. The interior knob/lever has a push-button locking feature. By pushing the button, the exterior knob/lever remains locked until it is unlocked by a key or by turning the interior knob. The exterior knob/lever can only be unlocked with a key. You state in your letter that while the decorative variations have different knob/lever designs and finishes, they have the same component types, same operation, same function and same manufacturer. Style A53 is packaged and sold unassembled with the following parts: an exterior door knob or lever assembly, an interior door knob or lever assembly, a spring latch bolt assembly, a keyed cylinder, a chassis, a strike plate, keys, and mounting hardware. This style does not include a deadbolt.
GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character. The keyed entry door devices are composed of two different components (a lock and a door handle) and are considered composite goods. The Explanatory Notes to the Harmonized Tariff Schedule of the United States (HTSUS), GRI 3 (b) (VIII), state that the factor which determines essential character will vary between different kinds of goods. It may for example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. When the essential character of a composite good can be determined, the whole product is classified as if it consisted only of the material or component that imparts the essential character to the composite good. In this case, it is the opinion of this office that the primary function of the subject keyed entry devices is to grasp, open and close a door. This function is provided by the knob/lever component.
The applicable subheading for the keyed entry door devices, style numbers W511 and A53, will be 8302.41.6045, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Base metal mountings, fittings and similar articles… Other mountings, fittings and similar articles, and parts thereof: Suitable for buildings: Other: Of iron or steel, of aluminum or of zinc… Suitable for interior and exterior doors (except garage, overhead or sliding doors): Other. The general rate of duty will be 3.9 percent ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Jennifer Jameson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division