Customs classification of compressor spring plates upheld under Heading 73.20 despite their use as machinery parts.

Spring plates imported for compressors were held to fall under Heading 73.20 as springs and leaves for springs of base metal, because the tariff scheme expressly treats such goods as parts of general use within Section XV. Even though the plates were manufactured to compressor specifications and functioned as identifiable machinery parts, the express tariff notes prevailed over any contrary HSN-based exclusion. The classification under Heading 8414.90 as parts of compressors was therefore rejected, and Heading 73.20 was sustained.

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Issues: Whether spring plates imported for use in compressors were classifiable under Heading 73.20 of the Customs Tariff Act as springs and leaves for springs of base metal, or under Heading 8414.90 as parts of compressors.

Analysis: The spring plates were manufactured to specification for compressors and were not of general use, but the tariff scheme expressly treats springs and leaves for springs of base metal as "parts of general use" under Section XV. Section XV excludes articles falling under Section XVI, yet the express notes to Sections XV and XVI bring springs and leaves for springs within Heading 73.20 even if they are identifiable parts of compressors. The exclusion urged from the HSN Explanatory Notes could not override the clear language of the Customs Tariff Act.

Conclusion: The spring plates were correctly classifiable under Heading 73.20 of the Customs Tariff Act and not under Heading 8414.90.

Final Conclusion: The challenge to the customs classification failed and the classification under Heading 73.20 was sustained.

Ratio Decidendi: Where the tariff entries and section notes expressly include springs and leaves for springs within Section XV, that express inclusion prevails over any contrary HSN-based exclusion, even if the goods are specially designed as parts of machinery.

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