Classification of cranking motors for I.C. engines upheld under heading 8409, applying Section Note 2(b) of Section XVI.

Heavy duty cranking motors used for internal combustion engines were treated as parts suitable solely and principally for use with I.C. engines, so they fell under heading 8409 rather than heading 8511. Applying Section Note 2(b) of Section XVI, parts must be classified with the machine of that kind unless a more specific heading governs them. As no specific heading was shown to require classification under heading 8511, the classification adopted by the Commissioner (Appeals) was upheld and the departmental appeal failed.

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Issues: Whether heavy duty cranking motors used for internal combustion engines were classifiable under heading 8409 as parts of engines, or under heading 8511 as electrical items.

Analysis: The product was a part suitable for use solely and principally with I.C. engines falling under headings 8407 or 8408. Under Section Note 2(b) of Section XVI, such parts are to be classified with the machines of that kind or in the appropriate heading specified in the note. As no specific heading was shown to govern the product under heading 8511, the classification adopted by the Commissioner (Appeals) was found to be correct.

Conclusion: The goods were correctly classifiable under heading 8409 and not under heading 8511, and the departmental appeal failed.

Ratio Decidendi: Parts suitable for use solely and principally with a specified machine are to be classified under the heading applicable to that machine in terms of Section Note 2(b) of Section XVI.

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