Actual function governs tariff classification of gas and air ratio valves, which are not pressure reducing valves.

Tariff classification depends on the true character of the goods as shown by their actual function. Gas and air ratio valves that regulate the flow of gas and air and maintain the proper ratio between them do not reduce pressure, so they cannot be treated as pressure reducing valves under Heading 84.61(2) of the Customs Tariff Act, 1975. The classification adopted by the lower authorities was therefore upheld, and the goods were held outside Heading 84.61(2).

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Issues: Whether gas and air ratio valves were classifiable as pressure reducing valves under Heading 84.61(2) of the Customs Tariff Act, 1975, or under Heading 84.61(1) or Heading 84.16(2) thereof.

Analysis: The determining factor was the actual function of the imported valves. On the material produced, the valves were meant to regulate the flow of gas and air and maintain the proper ratio between them. They did not reduce pressure, and therefore could not be treated as pressure reducing valves. The classification adopted by the lower authorities was consistent with the nature and function of the goods.

Conclusion: The goods were not pressure reducing valves and were not classifiable under Heading 84.61(2) of the Customs Tariff Act, 1975. The classification made by the lower authorities was upheld.

Ratio Decidendi: For tariff classification, the true character of the goods must be determined from their actual function, and a valve that merely regulates flow and maintains ratio without reducing pressure cannot be classified as a pressure reducing valve.

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