Classification of delivery valves in diesel pumps as pressure-reducing valves under Heading 84.81 confirmed over pump parts heading.

Delivery valves used in diesel fuel injection pumps were treated as pressure-reducing valves under Heading 84.81 because they regulate diesel at very high pressure and fit the description of valves covered by that heading. Heading 84.13, which covers pumps for liquids and their parts, was held inapplicable in view of Note 2(a) to Section XVI, under which goods specifically classifiable in Chapter 84 or 85 must be placed in their respective headings. Note 4 to Section XVI did not change that result. The goods were therefore classified under sub-heading 8481.80, not 8413.00.

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Issues: Whether delivery valves used in diesel fuel injection pumps are classifiable under Heading 84.81 as pressure-reducing valves or under Heading 84.13 as parts of pumps for liquids.

Analysis: Heading 84.81 covers taps, cocks, valves and similar appliances, including pressure-reducing valves, while Heading 84.13 covers pumps for liquids and parts thereof. The goods were found to be delivery valves required in diesel pumps to regulate diesel at very high pressure and therefore answered the description of pressure-reducing valves. Under Note 2(a) to Section XVI, parts which are goods included in any heading of Chapter 84 or 85 are to be classified in their respective headings. In view of that mandatory rule, Note 4 to Section XVI did not assist the respondent.

Conclusion: The goods are classifiable under sub-heading 8481.80 and not under sub-heading 8413.00, and the appeal succeeds in favour of the Revenue.

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