Machinery components classification prevails for specially cut stainless steel parts intended for digester lining.

Imported stainless steel items cut to specific sizes and marked with part numbers for lining paper mill digesters were treated as components of the paper-making machinery rather than as ordinary stainless steel sheets or plates. Applying the relevant Chapter 84 notes and the established interpretation of Heading 84.31, the Court held that goods specially prepared for incorporation into machinery and intended to function as its parts fall under the machinery heading instead of a general materials heading. The classification under Heading 84.31 was therefore maintained and the challenge failed.

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Issues: Whether the imported stainless steel items meant for lining the digester in a paper mill were classifiable under Heading 84.31 of the Customs Tariff, or under Heading 73.15(2) as stainless sheets/plates, or under Heading 84.64 as parts of machinery.

Analysis: The goods were cut to specific sizes and bore part numbers, showing that they were designed for use in lining the digesters and formed part of the paper-making machinery. In view of the earlier construction placed on Heading 84.31 and the relevant Chapter 84 notes, such specially prepared items were to be treated as components of machinery rather than as ordinary stainless steel sheets or plates.

Conclusion: The goods were rightly classified under Heading 84.31 of the Customs Tariff, and the challenge to that classification failed.

Final Conclusion: The appeal was rejected and the classification adopted by the Tribunal was maintained.

Ratio Decidendi: Goods specially cut and identified for incorporation into machinery, and intended to function as parts of that machinery, are classifiable as machinery components under the appropriate tariff heading rather than as general raw material or sheet goods.

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