Tariff classification of relays must follow functional capability, placing dual-voltage goods in the residual heading.

Imported relays capable of operating both below and above 60V could not be classified under Customs Tariff Item 85364100, which is confined to relays for voltages not exceeding 60V. On the technical record and literature, the goods were found to be usable beyond that limiting condition, so they fell outside the specific entry. The appropriate classification was therefore the residual heading, Customs Tariff Item 85364900, for relays not covered by the restricted provision. The revenue classification was set aside and relief was granted on classification.

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Issues: Whether relays capable of operating both below and above 60V were classifiable under Customs Tariff Item 85364100 or under Customs Tariff Item 85364900.

Analysis: The imported relays were found, on the basis of the record and technical literature, to be capable of use in voltages below 60V as well as above 60V. Customs Tariff Item 85364100 covers relays for voltages not exceeding 60V, whereas the competing entry was the residual category for relays other than those so confined. Since the goods were not restricted to operation only within the voltage limit contemplated by the specific entry, they could not be placed in that entry. The appropriate classification was therefore the broader entry for relays others.

Conclusion: The goods were not classifiable under Customs Tariff Item 85364100 and were classifiable under Customs Tariff Item 85364900.

Final Conclusion: The classification adopted by the revenue authorities was set aside and the appellant obtained relief on classification.

Ratio Decidendi: Where an imported product is capable of functioning beyond the limiting condition of a specific tariff entry, it cannot be classified under that restricted entry and must be placed in the appropriate residual heading.

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