Base-metal classification for unfinished refrigerator door handles: Heading 83.02 applied, not castings or refrigerator parts.

Cast zinc refrigerator door handles, after fettling but before chrome plating, were treated as more than raw castings, yet not as complete refrigerator parts because further finishing remained. Rule 2(a) of the General Interpretative Rules was considered inapplicable since the goods did not yet possess the essential character of finished refrigerator parts. The classification under Heading 79.07 was rejected, and the interpretative notes on base-metal fittings supported classification as articles of base metal under Heading 83.02. Differential duty followed on that basis.

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Issues: Whether cast zinc refrigerator door handles, after fettling and before chrome plating, were classifiable as castings under Heading 79.07, as parts of refrigerators under Heading 84.80, or as articles of base metal under Heading 83.02; and whether Rule 2(a) of the General Interpretative Rules applied to treat the goods as finished or unfinished parts having the essential character of the complete article.

Analysis: The goods were not mere castings once they had undergone working sufficient to move beyond raw metal castings, but they were not complete refrigerator parts either, as chrome plating remained to be done. Applying the principle that unfinished or incomplete parts fall under the heading of the finished article only when they possess the essential character of that article, the goods were held not to fit Heading 79.07. The interpretative notes relating to general purpose base-metal fittings supported treatment of door handles as articles of base metal, and Heading 83.02 was found to be the more appropriate classification.

Conclusion: The classification under Heading 79.07 was rejected, and the goods were held classifiable under Heading 83.02, with differential duty payable accordingly.

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