Home Depot U.S.A., Inc. v. United States
2017 CIT 129
| Ct. Intl. Trade | 2017Background
- Home Depot imported keyed entry door knob locksets (entry locks) entered in 2012 and liquidated by Customs in 2013; Customs classified them under HTSUS 8301.40.6030 (locks) at 5.7% duty; Home Depot sought classification under HTSUS 8302.41.6045 (mountings/knobs) at 3.9% duty.
- The imported units were packaged as complete locksets: exterior and interior knobs with trim, a spring-loaded latch in a frame, a keyed cylinder in the exterior knob, a thumbturn on the interior knob, strike plate, keys, and installation hardware.
- Home Depot marketed the products as "knobs" or "knobsets" on its website but product descriptions referenced "this lock," included keyed entry components, and listed ANSI/BHMA testing/certification.
- ANSI/BHMA Standard A156.2 (used to test these models) describes entry locks as multi-component devices including a latch, keyed cylinder, and operating trim (knob/lever), and treats knobs/levers as parts of a lock.
- The parties cross-moved for summary judgment; the court found no material dispute of fact about the merchandise and resolved classification as a matter of law under the HTSUS General Rules of Interpretation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the subject articles are classifiable under HTSUS heading 8302 (base metal knobs/mountings) | Home Depot: the products are door knobs/knobsets and thus eo nomine covered by 8302; any locking feature is an improvement and does not change identity | U.S.: the assemblies are "locks" (multi-part devices with bolt and mechanism) and therefore fall within heading 8301 | Held: No — 8302 at most describes the knob components, but not the articles in whole; the complete articles are locks under 8301 |
| Whether the articles are classifiable under HTSUS heading 8301 (locks, key-operated) | Home Depot: the key does not directly propel the latch; the latch is withdrawn by turning the knob, so not "key-operated" in the requisite sense | U.S.: dictionary, ENs, and ANSI/BHMA standards show a lock can be multi-component and that knobs/levers are operating parts; a key that enables unlocking operates the device | Held: Yes — the assemblies are key-operated locks within the common commercial meaning and the ENs; heading 8301 describes the articles in whole |
| Whether the items are prima facie classifiable under multiple headings such that GRI 3 applies | Home Depot: argues classification under 8302 is appropriate (which would create multiplicity) | U.S.: contends GRI 1 resolves classification to 8301 because the goods are locks as described | Held: GRI 1 dispositive — goods are described in whole by heading 8301, so GRI 3 need not be reached |
| Whether Customs' subheading choice (8301.40.6030: door locks/locksets suitable for interior/exterior doors) was correct | Home Depot: sought lower-duty subheading under 8302 | U.S.: Customs selected 8301.40.6030 consistent with product function and ENs | Held: Yes — subheading 8301.40.6030 is appropriate; summary judgment for Government granted |
Key Cases Cited
- Bausch & Lomb, Inc. v. United States, 148 F.3d 1363 (Fed. Cir.) (classification framework — heading construction is question of law)
- Mita Copystar Am. v. United States, 160 F.3d 710 (Fed. Cir.) (GRIs applied in numerical order)
- CamelBak Prods., LLC v. United States, 649 F.3d 1361 (Fed. Cir.) (eo nomine provisions include all forms unless difference in identity/character is significant)
- La Crosse Tech., Ltd. v. United States, 723 F.3d 1353 (Fed. Cir.) (article excluded from eo nomine when in character or function something other than described)
- Rocknel Fastener, Inc. v. United States, 267 F.3d 1354 (Fed. Cir.) (industry standards are legitimate interpretive resources)
- Rollerblade, Inc. v. United States, 282 F.3d 1349 (Fed. Cir.) (definition of "part" and classification with parent article)
- Skidmore v. Swift & Co., 323 U.S. 134 (U.S.) (administrative determinations weigh under Skidmore)
- United States v. Mead Corp., 533 U.S. 218 (U.S.) (Chevron deference not afforded to Customs classification rulings)