Tariff classification of canoe paddles turns on chapter notes excluding propulsion items and applying material-based heading treatment.

Carbon-fibre paddles used to propel canoes are excluded from Chapter 89 because separately presented vessel parts and accessories do not cover paddles, and they are also excluded from Chapter 95 because the sports-craft heading does not extend to means of propulsion. As the paddles do not fall within Chapter 95 on the combined effect of the chapter notes, they are classified according to their material composition. The classification under Chapter 89 was rejected, the Chapter 95 claim failed, and heading 68151090 under Chapter 68 was upheld.

---

---

Issues: (i) Whether carbon-fibre paddles for canoes are classifiable under Chapter 89, Chapter 95, or Chapter 68 of the Customs Tariff.

Analysis: Chapter 89 excludes separately presented parts and accessories of vessels, and the cited explanatory notes indicate that paddles and similar propulsion items are not classifiable as parts of boats and canoes under that chapter. Chapter 95 also excludes sports craft such as canoes and their means of propulsion, with wooden propulsion items being specifically referred to elsewhere; the exclusion is not confined to wooden paddles alone. Chapter 68, in turn, excludes articles of Chapter 95, but the paddles in question do not fall within Chapter 95 on the combined effect of the relevant chapter notes. Since the goods are paddles made of carbon fibre, they are classifiable according to the material-based heading applicable to such articles.

Conclusion: Classification under Chapter 89 and Chapter 95 is rejected, and the goods are correctly classifiable under heading 68151090.

Final Conclusion: The impugned classification placing the goods under Chapter 89 was set aside, the claim for classification under Chapter 95 failed, and the Revenue's classification under Chapter 68 was upheld.

Ratio Decidendi: Separately presented paddles used as the means of propulsion of canoes are excluded from Chapter 89 and from Chapter 95, and where they do not fall within the sports-requisites chapter they are classified under the heading appropriate to their material composition.

---