Tariff classification of flocked fabric turns on specific heading for fabrics covered with textile flocks over printed fabric.

Flocked fabric was disputed under tariff classification: whether it fell under Heading 54.09 as printed fabric or under Heading 59.06 as fabric covered partially or fully with textile flocks or preparations containing textile flocks. A harmonious reading of the headings gave effect to the specific wording in Heading 59.06, which would be undermined if flocking were treated only as printing under Heading 54.09. The analysis distinguished fabrics printed by flocking from fabrics actually covered with textile flocks. The goods were therefore classified under Heading 59.06 and not Heading 54.09.

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Issues: Whether flocked fabric manufactured by the assessee was classifiable as printed fabric under Heading 54.09 or as fabric covered partially or fully with textile flocks or preparations containing textile flocks under Heading 59.06.

Analysis: The product was described as flocked fabric, and flock printing was relied upon as a form of printing. A prior tribunal ruling and a tariff advice treating flock-printed textiles as printed textile supported the assessee's contention. However, the tariff in question contained a specific entry in Heading 59.06 covering fabrics covered partially or fully with textile flocks or with preparations containing textile flocks. If such goods were brought under Heading 54.09 merely because the process involved printing by flocking, the specific words in Heading 59.06 would be rendered redundant. On a harmonious reading of the headings, Heading 54.09 would cover fabrics printed otherwise by way of flocking, while the more specific heading would govern fabrics actually covered with textile flocks or preparations containing textile flocks.

Conclusion: The goods were correctly classifiable under Heading 59.06 and not under Heading 54.09; the appeal failed.

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