OT:RR:NC:N5:121
George Tuttle, III
Tuttle Law Offices
3950 Civic Center Dr, Ste 102
San Rafael, CA 94903
RE: The country of origin of a Locking Door Latch Set
Dear Mr. Tuttle, III:
In your letter dated January 30, 2026, you requested a country of origin ruling on a Locking Door Latch Set
on behalf of Taiwan Fu Hsing Industrial Co., Ltd. Photographs and descriptions of this item were submitted
with your inquiry.
The Locking Door Latch Set is made primarily of steel and consists of the latch assembly, the strike plate,
and the inside and outside knob or lever assemblies that are packaged together for sale and ready for
installation. The latch assembly, the strike plate, and the inside and outside knob or lever assemblies are each
separate pieces and not attached to each other within the packaging. These Locking Door Latch Sets are
available with either doorknobs or door lever handles and are typically used with interior residential doors
and exterior doors.
You have proposed a manufacturing scenario in which the knobs or levers and the strike plates are
manufactured in Taiwan. The keyed cylinder system (key assembly) will be assembled in Taiwan using the
key, spring, and pins that are sourced in Taiwan; the cylinder plug and plug housing that are sourced in
Taiwan, Thailand and/or China; and the buckle, plug housing cap, stopper and plug housing sticker that are
sourced in Thailand and/or China. The knobs or levers, strike plates, and key assemblies would then be
exported to Thailand and/or China and assembled with the latch assembly, and the internal and external
subassemblies of Thai or Chinese origin. The completed Locking Door Latch Set 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).
It is this office’s opinion that the primary function of the Locking Door Latch Set is to grasp, open and close
the door, a function that is provided by the doorknob or lever component. The doorknobs or levers, the strike
plate, and they key assembly which originate in Taiwan, provide the essential operation element for the
Locking Door Latch Set to work. These items are not substantially changed by the addition of the latch
assembly and internal and external subassemblies of Thai and/or Chinese origin. In view of these facts, the
country of origin for the Locking Door 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)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division