Customs tariff classification of relief valves depended on their factual nature, leading to remand for fresh adjudication.

Classification of imported relief valves under the Customs Tariff turned on the factual question whether they were pressure reducing valves under Heading 84.61(2) or integral parts of machinery under Heading 84.10(3). The record did not contain a clear finding on that essential factual characterisation, so the dispute could not be conclusively decided on merits. In the absence of a definitive determination of the goods' nature, the matter was remitted for fresh adjudication on a de novo basis.

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Issues: Whether the imported goods, described as relief valves, were classifiable as pressure reducing valves under Heading 84.61(2) of the Customs Tariff Act or as an integral part of machinery under Heading 84.10(3), and whether the matter required remand for fresh adjudication.

Analysis: The classification depended on the factual nature of the goods. If the goods were pressure reducing valves, Heading 84.61(2) would apply; if they were integral parts of the machinery, Heading 84.10 would govern. The lower authorities had not recorded a clear finding on the essential factual question whether the goods were pressure reducing valves. In the absence of such a finding, the dispute could not be finally resolved on the existing record.

Conclusion: The classification issue was not finally determined on merits and the matter was remitted for a de novo decision.

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