Tariff classification of unfinished fan parts turns on essential character, with specific fan heading prevailing over residuary steel entry.

Incomplete or unfinished imported impeller rings were treated as component parts of induced draught fans because they had the essential character of the finished fan assembly under Rule 2A of the tariff interpretation rules. The specific tariff heading for exhaust fans and blowers prevailed over the residuary iron and steel heading, so the goods were classifiable under Heading 84.11(4) rather than Heading 73.33/40. The classification issue was resolved in favour of the assessee.

---

---

Issues: Whether impeller rings, being incomplete or unfinished component parts of induced draught fans, were classifiable under the residuary iron and steel heading or under the specific heading for exhaust fans and blowers.

Analysis: The impeller rings were shown to be component parts of induced draught fans. Heading 73.33/40 was residuary in nature, whereas Heading 84.11(4) specifically covered exhaust fans and blowers of the relevant sweep. Under Rule 2A of the Rules for the Interpretation of the First Schedule of the Import Tariff, an incomplete or unfinished article is to be treated as the complete article if, as imported, it has the essential character of the finished article. On the facts, the imported impeller rings had the character of parts of the finished fan assembly.

Conclusion: The goods were rightly classifiable under Heading 84.11(4) and not under Heading 73.33/40; the appeal was therefore allowed in favour of the assessee.

Ratio Decidendi: An incomplete or unfinished imported article is classifiable as the complete article when it has the essential character of the finished product, and a specific tariff entry prevails over a residuary entry.

---