Essential character test upheld for composite bobbins, with aluminium treated as the decisive component for tariff classification.

Composite flanged bobbins made from an aluminium tube with plastic flanges were classified by applying Rule 3(b) on essential character, because the aluminium tube was the component that gave the article its functional identity as a bobbin and the plastic flanges were merely ancillary support. The section and chapter notes relied on by the assessee did not displace that tariff principle. Accordingly, the goods were treated as articles of aluminium under Heading 7616.90, and the duty demand based on reclassification was upheld.

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Issues: Whether flanged bobbins made of an aluminium tube with plastic flanges were correctly classifiable as articles of aluminium under Heading 7616.90, and whether the duty demand based on reclassification was sustainable.

Analysis: The classification dispute turned on which constituent material gave the composite item its essential character. The bobbins were described as having an aluminium rod or tube on which yarn was wound, while the plastic flanges were only attached at either end for support, protection, and convenience. Applying Rule 3(b) of the rules for interpretation of tariff classification, composite goods are to be classified as if they consisted of the material or component that gives them their essential character. On that basis, the aluminium tube was held to be the component that enabled the bobbin to function as a bobbin, and the section and chapter notes relied upon by the assessee did not displace that principle.

Conclusion: The bobbins were correctly classified as articles of aluminium under Heading 7616.90, and the demand of duty based on reclassification was upheld.

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