Motor vehicle seat parts classified under specific heading 9401, not general motor vehicle parts heading 8708

Imported child parts used to manufacture round recliner assemblies for motor vehicle seats were held to fall under heading 9401, because that heading specifically covers seats of motor vehicles and their parts. Heading 8708 was only a general entry for motor vehicle parts and accessories, and the Section XVII notes excluded goods more specifically covered elsewhere in the tariff. As the parts were integral to seat manufacture and the later stages of production were also treated under heading 9401, classification under heading 8708 was not permitted merely because the finished seat was used in a motor vehicle.

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Issues: Whether the imported child parts used in making round recliner assemblies for motor vehicle seats were classifiable under heading 9401 as parts of seats or under heading 8708 as parts and accessories of motor vehicles.

Analysis: The tariff scheme showed a specific entry for seats of motor vehicles and parts thereof under heading 9401, while heading 8708 was a general entry for motor vehicle parts and accessories. The section notes to Section XVII excluded vehicle seats of heading 9401 from classification under that section when more specifically covered elsewhere in the nomenclature. The HSN explanatory notes for heading 8708 also required that the goods not be excluded by the notes to Section XVII. On the facts, the imported child parts were used in manufacture of round recliners, which were integral parts of motor vehicle seats, and the subsequent stages of manufacture were also treated under heading 9401. The goods were therefore more specifically covered by heading 9401 and could not be shifted to heading 8708 merely because the finished seat was used in a motor vehicle.

Conclusion: The imported child parts were correctly classifiable under heading 9401 90 00 and not under heading 8708.

Ratio Decidendi: Where a tariff item specifically covers seats of motor vehicles and their parts, and the section notes exclude such goods from a general motor vehicle parts heading, the specific heading governs classification.

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