Interchangeable tools test limits tariff classification of die sets, which were classified as parts and accessories instead.

Press tools and die sets imported for use in power presses were held not to be interchangeable tools for Heading 82.05 of the Customs Tariff Act, because interchangeability requires a tool to be usable in place of another to perform the same function. On the admitted facts, each die set could produce only one specific watch part, could not do any other job, and no other tool could replace it for that purpose. The fact that a worn die could be replaced by another die of the same type was treated as a common feature of standard machine parts and was insufficient to satisfy the tariff requirement. The goods were therefore classifiable under Heading 84.45/48 as parts and accessories.

---

---

Issues: Whether the press tools or die sets imported for use in power presses were classifiable under Heading 82.05 of the Customs Tariff Act, 1975 as interchangeable tools, or under Heading 84.45/48 as parts and accessories suitable for use solely or principally with machine tools.

Analysis: Heading 82.05 is not confined to hand tools and extends to interchangeable tools for machine tools. The decisive question, however, was whether the goods themselves satisfied the requirement of interchangeability. Interchangeability was held to mean suitability of one product to be used in place of another to fulfil the relevant requirements. On the admitted facts, each die set could manufacture only one particular watch part, could not do any other job, and no other tool could take its place and perform the same function. Replacement of one worn die by another die of the same type was treated as a characteristic common to standard machine parts and not enough by itself to satisfy the tariff requirement of interchangeability.

Conclusion: The die sets were not interchangeable tools and did not fall under Heading 82.05. They were properly classifiable under Heading 84.45/48.

---