Material-based tariff classification prevails for composite fibre glass vessels over end-use as water treatment plant parts.

Composite fibre glass pressure vessels and related components are analysed as goods whose finished products contained glass fibre as the predominant material. The text explains that where the tariff contains a specific entry based on the material of manufacture, classification must follow that material-specific heading rather than end use as a part of a water treatment plant. It further notes that Note 2(a) to Section XVI and Chapter Note 1(c) to Chapter 84 support exclusion from Chapter 84 where Heading 70.14 applies. The rival essential-character and end-use approach is distinguished on these facts, and the material-based classification prevails.

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Issues: Whether fibre glass pressure vessels and related components were classifiable under Heading 70.14 as goods of glass fibre on the basis of predominant material, or under Heading 84.21 as parts of water treatment plants on the basis of end use and essential character.

Analysis: The goods were composite in nature, but the record showed that glass fibre constituted the predominant material in the finished products. Where a specific tariff entry exists for the material of manufacture, classification must follow that specific entry rather than the end use of the article. Note 2(a) to Section XVI and Chapter Note 1(c) to Chapter 84 supported exclusion of goods classifiable under Heading 70.14 from Chapter 84. The reasoning that classification should turn on essential character based on end use was distinguished on the facts, as the rival entries here turned on predominant material versus use as a component of machinery.

Conclusion: The goods were correctly classifiable under Heading 70.14 and not under Heading 84.21. The Commissioner (Appeals) order was unsustainable.

Final Conclusion: The Revenue's challenge succeeded and the duty demand classification under Heading 70.14 was restored.

Ratio Decidendi: For composite goods, where the tariff provides a specific entry based on the predominant material, classification must follow that material-based entry and not the article's end use or treatment as a machine part.

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