OT:RR:NC:N5:121
George Tuttle, III
Tuttle Law Offices
3950 Civic Center Drive, Ste 102
San Rafael, CA 94903
RE: The country of origin of a Non-Locking Doorknob Latch Set
Dear Mr. Tuttle, III:
In your letter dated December 2, 2025, you requested a country of origin ruling on a Non-Locking Doorknob
Latch Set on behalf of Taiwan Fu Hsing Industrial Co., Ltd.
The article under consideration is described as a Non-Locking Doorknob Latch Set. The set is made primarily
of steel and consists of an inside knob assembly, an outside knob assembly, a latch assembly, and a strike
plate that are packaged together for sale and ready for installation. The inside and outside doorknob
assembly, the strike plate, and the latch assembly are each separate pieces and not attached to each other
within the packaging.
You describe a manufacturing process in which the internal and external components of the doorknob
assembly, which include the spindle, rose, tab, spring cage, and coupler assemblies, and the latch assemblies
are produced in Thailand and/or China. Those components are shipped to Taiwan where they will be
assembled together with Taiwan-origin doorknobs and the strike plate to create the Non-Locking Doorknob
Latch Set. The set is then packaged in Taiwan and shipped to the U.S.
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).
It is this office’s opinion that the primary function of the Non-Locking Doorknob Latch Set is to grasp, open
and close the door, a function that is provided by the doorknob component. The doorknobs and strike plate,
which originate in Taiwan, and the doorknob assemblies that are assembled in Taiwan provide the essential
operation element for the doorknob latch set to work. In view of these facts, the country of origin for
Non-Locking Doorknob Latch Set is 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 [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division