Motor vehicle seat fittings classified as accessories, not seat parts, because they were adjuncts for comfort and use.

Rail assembly front seat adjusters, assembly sliders and rear back seat lock assemblies were treated as accessories rather than parts of seats because they merely improved adjustment, comfort and convenient use and were not essential components of the seats. The decisive distinction was that a part is integral to the main article, while an accessory is only an addition or adjunct. On that basis, the goods were classifiable as accessories of motor vehicles under Chapter Heading 8708 and not as parts of seats under Chapter Heading 9401, so the demand founded on the contrary classification could not be sustained.

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Issues: Whether rail assembly front seat adjuster/assembly slider seat and rear back seat lock assembly are to be classified as parts of seats under Chapter Heading 9401 of the Central Excise Tariff or as accessories of motor vehicles under Chapter Heading 8708.

Analysis: The items were found to be mechanisms that enabled adjustment and convenient use of the seats, but they were not essential components of the seats. The seats were complete and usable without them. Applying the distinction between parts and accessories, the decisive test was whether the goods were essential pieces of the seat or merely additions, adjuncts, or accompaniments for comfort and convenience. The goods were held to fall in the latter category. Since they were accessories used in automobiles, and Chapter Heading 8708 covers parts and accessories of motor vehicles, they could not be classified as parts of seats under Chapter Heading 9401.

Conclusion: The goods were correctly classifiable as accessories under Chapter Heading 8708 and not as parts of seats under Chapter Heading 9401, and the demand based on the contrary classification could not be sustained.

Ratio Decidendi: An article is an accessory, not a part, when it is only an adjunct or addition for convenient use or comfort and is not an essential component of the main article; accessories of a motor-vehicle part are classifiable within the scope of Chapter Heading 8708.

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