RE: The country of origin of a single cylinder deadbolt lockset

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363908 August 28, 2026 OT:RR:NC:N5:121 CATEGORY: Origin George Tuttle, III Tuttle Law Offices 3950 Civic Center Dr, Ste 102 San Rafael, CA 94903 RE: The country of origin of a single cylinder deadbolt lockset Dear Mr. Tuttle, III: In your letter dated July 31, 2026, you requested a country of origin ruling for a single cylinder deadbolt lockset on behalf of Taiwan Fu Hsing Industrial Co., Ltd. Photographs and descriptions of the merchandise and manufacturing process were included in your inquiry. The article under consideration is identified as a Single Cylinder Deadbolt Lock. It consists of five main components: an outside key assembly, a latch assembly, a strike plate, an internal assembly, and an external assembly that are packaged together for sale and ready for installation. The function of this item is to lock and secure a door. It has a keyed lock on the outside of the door and a thumb-turn lever on the inside of the door. You have proposed a manufacturing scenario in which the cylinder plug, drive rod, plug cap, outside cylinder housing, stopper, and buckle are manufactured in China. Those components are shipped to Taiwan where they are assembled together. Then an operator in Taiwan loads the assembly onto a semi-automatic pinning machine and inserts the key of Taiwan origin into the Chinese plug. The machine detects the key bitting code and selects and inserts the corresponding pins and springs of Taiwan origin so that the cylinder will rotate when the correct key is inserted. The outside key assembly is tested, and then, along with the strike plate and thumb turn from Taiwan, is exported to China. In China, the latch and external assemblies are produced using components from China, and the thumb turn from Taiwan is assembled with the Chinese trim to produce the internal subassembly. Those components are then packaged together with the outside key assembly and the strike plate for export 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).
In this instance, it is this office’s opinion that the outside key assembly provides the essence of this lockset because it provides the locking mechanism of this fastening device. And the cylinder plug and outside cylinder housing provide the essence of the outside key assembly. It is our opinion that the cylinder plug and outside cylinder housing are not substantially changed by the simple assembly nor the pinning operation performed in Taiwan. The China-produced cylinder plug, outside cylinder housing, latch and the external assembly would provide the essential operational elements for the Single Cylinder Deadbolt Lock to work. In view of these facts, the country of origin of the Single Cylinder Deadbolt Lock would be China. 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 P. Forkan Director National Commodity Specialist Division