Specific tariff heading prevails for lawn mowers, with Heading 8433 upheld over the broader hand-tool classification.

Imported lawn mowers were held classifiable under Heading 8433 because that heading specifically covers grass or hay mowers and the Explanatory Notes include lawn mowers. Heading 8467, which is directed to tools for working in the hand, was treated as the more general entry and its exclusionary notes refer to electric lawn mowers. Applying the principle that a specific tariff description prevails over a broader competing heading, the importer's classification under Heading 8433 was upheld and the contrary assessment was set aside.

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Issues: Whether the imported lawn mowers were classifiable under Heading 8433 or Heading 8467 of the Customs Tariff.

Analysis: Heading 8433 specifically covers grass or hay mowers and the Explanatory Notes include lawn mowers within that heading. Heading 8467 covers tools for working in the hand and is oriented to portable hand-held or hand-directed tools, while its exclusionary notes specifically refer to electric lawn mowers. Applying the principle that a specific mention excludes what is different from it, the more specific tariff entry for lawn mowers governed the classification.

Conclusion: The imported goods were correctly classifiable under Heading 8433 and not under Heading 8467.

Final Conclusion: The classification adopted by the importer was upheld and the contrary assessment was set aside.

Ratio Decidendi: Where goods are specifically covered by a tariff heading, that specific classification prevails over a competing general heading, particularly when the latter's own explanatory notes exclude the goods in question.

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