8301Padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames with clasps, incorporating locks, of base metal; keys for any of the foregoing articles, of base metal
SP
Manufacture from materials of any heading, except that of the good.
OR - alternative rule
MaxNOM
Manufacture in which the value of all the materials used does not exceed 70% of the ex-works price of the good.