Tariff classification of low aromatic naphtha requires proof of every essential entry condition, not just technical test parameters.

For tariff classification of low aromatic naphtha, the product had to satisfy every essential element of the claimed Special Boiling Point Spirits entry, including the relevant heading description and not merely the distillation parameters. Although test results showed compliance with the distillation-based requirements, the Revenue did not establish that the goods answered the motor spirit description required by the tariff scheme. Classification could not rest on partial conformity with technical parameters alone, so the claim that the product fell under the special boiling point spirit entries was not proved.

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Issues: Whether Low Aromatic Naphtha was classifiable as Naphtha or as Special Boiling Point Spirits under the tariff entries applicable before and after 1 March 2005.

Analysis: The tariff scheme treated Special Boiling Point Spirits as light oils not containing anti-knock preparations and satisfying the stipulated distillation parameters, but classification under the relevant entries also required the goods to answer the description in the single-dash entry for motor spirit. The test results showed that the product met the distillation-based requirements of Special Boiling Point Spirits, but the Revenue did not establish that the goods satisfied the motor spirit description. Classification could not be sustained merely because the product satisfied part of the tariff description; the Revenue had to prove all conditions necessary for the claimed heading.

Conclusion: The product was not proved to fall under the special boiling point spirit entries as claimed by the Revenue, and the appeal failed.

Ratio Decidendi: For tariff classification, the Revenue must prove that the goods satisfy every essential element of the claimed entry, including the description in the relevant heading, and not merely selected technical parameters.

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