Water filter parts classification favors Heading 84.21 over steel household articles, defeating the exemption claim.

Stainless steel top, bottom and lid components of a domestic water filter were held classifiable as parts of filtering or purifying apparatus for water under Heading 84.21, because the assembly's essential function was water filtration through a porous ceramic element. The tariff entry for filtering and purifying machinery for liquids, including domestic water filters, was treated as the specific classification and prevailed over the general entry for household articles of steel under Heading 73.23. On that basis, the components were not eligible for the exemption claimed under Notification No. 4/97-C.E., as the classification did not fall within the asserted heading.

---

---

Issues: Whether the stainless steel top, bottom and lid portions of the water filter were classifiable as parts of other household articles of steel under Heading 73.23, or as parts of filtering or purifying apparatus for water under Heading 84.21, and consequently whether the benefit of Notification No. 4/97-C.E. dated 1-3-1997 was available.

Analysis: The goods were parts of a water filter assembly consisting of a ceramic candle enclosed in a steel container with a tap outlet. The essential function of the assembly was filtration of water through a porous ceramic element. Heading 84.21 specifically covers filtering and purifying machinery and apparatus for liquids, including domestic water filters, and the HSN Notes support classification of such domestic appliances under that heading. Since Heading 84.21 is the specific entry for water filters, the components of the assembly are classifiable as parts of filtering or purifying apparatus for water rather than as household articles of steel under Heading 73.23.

Conclusion: The goods were classifiable under Heading 84.21 as parts of filtering or purifying apparatus for water, and not under Heading 73.23. The exemption claim based on Notification No. 4/97-C.E. was therefore not available.

Ratio Decidendi: Where a product is specifically covered by a tariff entry as a filtering or purifying apparatus for water, its constituent parts must be classified under that specific entry rather than under a more general entry for household articles of steel.

---