US Agrees to Lower Duty Rate on Home Depot's Door Knob and Deadbolt Packages

The Court of International Trade on May 20 entered stipulated judgment in a pair of customs suits brought by Home Depot U.S.A., lowering the duty rate on the retail giant's imported residential door knobs packaged with at least one deadbolt, from 5.7% to 3.9% (Home Depot U.S.A. v. United States, CIT Consol. # 14-00122, -00123).

CBP classified the goods, which are combination door knob and deadbolt sets marketed as the Defiant brand, under Harmonized Tariff Schedule subheading 8301.40.60, which is the heading for locks used with interior or exterior doors. Home Depot brought suit claiming the entries properly fit under subheading 8302.41.60, which provides for "metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like" (see 2210310078).

Home Depot used General Rule of Interpretation 3(b) to make its case, since the rule says that goods made of multiple articles, each of which has its own HTS heading, can be classified under one tariff provision if the goods meet three distinct criteria. As such, the goods must be made of at least two different articles under two different headings, made of articles put together to carry out a specific task and put up in a way suitable for the direct sale to users without repackaging. Home Depot said its goods fit all three criteria.

The U.S. and the retailer last week filed a joint motion for entry of stipulated judgment, agreeing to classify "certain models of the imported merchandise" under subheading 8302.41.60. Home Depot said "it wishes to abandon its claims for the remaining models of the imported merchandise." Judge Leo Gordon entered the subsequent judgment.