Classification of plastic vehicle name plates and emblems as articles of plastics upheld over motor vehicle parts heading.

Plastic name plates, labels and emblems designed for motor vehicles were treated as articles of plastics rather than parts of motor vehicles, because they were affixed only for identification or branding and did not affect the vehicle's completeness or functionality. The fact that the items were specially designed for particular vehicles did not change their essential character for tariff purposes. Heading 39.26, covering articles of plastics, was held to be the appropriate classification, and Chapter 87 for motor vehicle parts was rejected.

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Issues: Whether plastic name plates, labels and emblems designed for use on motor vehicles and motor cycles were classifiable as parts of motor vehicles under Chapter 87 or as articles of plastics under Heading 39.26.

Analysis: The goods were made of plastic and were affixed only for identification or branding purposes. A motor vehicle remains complete and functional without such items, so they do not answer the description of parts of motor vehicles. The cited authority on name plates did not hold that a name plate becomes a part of the final product; it treated the item as an input used in relation to manufacture. The fact that the goods were specially designed for particular vehicles or that similar matters were decided differently by other authorities did not alter the proper classification on merits. Heading 39.26 specifically covers articles of plastics and was the appropriate heading for the impugned goods.

Conclusion: The goods were correctly classifiable under Heading 39.26 of the Central Excise Tariff Act, 1985 and not under Chapter 87. The appeal failed.

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