Tariff classification of filter elements as parts under Heading 8421.90, not complete apparatus, was upheld.

A filter element cleared as a component of a filter assembly was held classifiable under Heading 8421.90 as parts, not under Heading 8421.10 as a complete filtering or purifying apparatus. The classification turned on the tariff scheme distinguishing complete apparatus from parts, with Section Note 2(a) of Section XVI and the interpretative rules applied to avoid making the parts heading redundant. Technical material showed that the item did not function independently, but only in conjunction with other assembly components for filtration. The majority therefore affirmed the lower authority's classification and duty demand, and the appeals were dismissed.

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Issues: Whether the filter element is classifiable under Heading 8421.10 as a complete filtering or purifying apparatus, or under Heading 8421.90 as parts of such apparatus.

Analysis: The tariff scheme under Heading 8421 distinguishes between "all goods other than parts" and "parts". The material on record showed that the item was cleared as a filter element forming part of a filter assembly, and that it functioned in conjunction with other components of the assembly. The interpretative rules and Section Note 2(a) of Section XVI were applied to hold that a part which is itself covered by a specific heading must be classified according to that heading, and that the separate heading for parts cannot be rendered redundant. The technical literature also indicated that the filter element did not operate independently as a complete apparatus, but as a component of the assembly used for filtration.

Conclusion: The filter element is classifiable as parts under Heading 8421.90 and not as a complete filtering or purifying apparatus under Heading 8421.10.

Final Conclusion: The majority affirmed the lower authority's classification and the duty demand, resulting in dismissal of the appeals.

Ratio Decidendi: Where a product is separately cleared as a component of a machine and does not function independently as a complete apparatus, it must be classified under the specific tariff entry for parts rather than under the entry for complete machinery or apparatus.

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