Specific tariff classification prevails for drum closures and seals as packing accessories rather than container parts.

Industrial drum closures, flanges, bungs, gaskets, tag rings, plugs, screw nozzles, screw caps and inner seals were treated as packing accessories used for fitment, sealing and security of containers. Heading 83.09, covering stoppers, caps, lids, seals and similar base-metal packing accessories, was held to be the more specific classification than Heading 83.12 for base-metal containers. On the facts, Note 1 to Chapter 83 did not change that result. The items were therefore classifiable under sub-heading 8309.90 and not under sub-heading 8312.12.

---

---

Issues: Whether the disputed drum closures, flanges, bungs, gaskets, tag rings, plugs, screw nozzles, screw caps and inner seals were classifiable as packing accessories under Heading 83.09 or as parts of containers under Heading 83.12.

Analysis: The goods were found, on the basis of the product literature and the nature of the items, to be closures and fittings used for fitment on drum tops and for sealing and security of industrial containers. Heading 83.09 specifically covers stoppers, caps, lids, seals and other packing accessories of base metal, whereas Heading 83.12 is a more general entry for containers of base metal. Since the disputed items answered the description of packing accessories more specifically, the specific tariff entry was held to prevail over the general container heading. Note 1 to Chapter 83 did not alter that result on the facts found.

Conclusion: The items were classifiable under sub-heading 8309.90 and not under sub-heading 8312.12. The assessee succeeded.

Ratio Decidendi: Where goods are specifically described by one tariff entry as packing accessories, that specific entry prevails over a more general entry for containers.

---