Tariff classification of diagnostic reagent strips turned on their paper-based character at import, not their later medical use.

Imported reagent strips were classified by reference to their character at the time of importation: they consisted of sheets of filter paper impregnated with chemicals, later attached to plastic strips for diagnostic use. Because the imported goods themselves remained recognisable as paper-based sheets and needed the strip and colour chart for practical use, they did not qualify as complete medical instruments or appliances under Heading 90.17/18. The general heading for chemical products also could not displace the more specific tariff description. The specific heading for impregnated paper prevailed, and the goods were correctly classified under Heading 48.01/21 of the Customs Tariff Schedule.

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Issues: Whether the imported reagent strips were classifiable under Heading 90.17/18 as medical instruments and appliances or, alternatively, under Heading 38.01/19 as chemical products, instead of under Heading 48.01/21 as impregnated paper or paper board.

Analysis: The decisive question was the character of the goods at the time of importation. The imported material was in the form of sheets of filter paper impregnated with chemicals and only later attached to plastic strips for use as diagnostic reagent strips. The finished marketed article could serve a diagnostic purpose, but the imported goods by themselves were still recognisable as paper-based sheets and required the accompanying strip and colour chart for practical use. On that footing, they did not answer to the description of medical appliances, which connotes complete instruments or apparatus, nor could the general heading for chemical products prevail over the more specific tariff description. The specific heading for impregnated paper was the appropriate classification, and the interpretative principle favouring the most specific description supported that result.

Conclusion: The imported goods were correctly classified under Heading 48.01/21 of the Customs Tariff Schedule and not under Heading 90.17/18 or Heading 38.01/19.

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