Composite goods classification: bullet proof doors and windows with aluminium frames fall under aluminium doors and windows, not glass articles.

Bullet proof doors and windows with aluminium frames and glass were held classifiable by their commercial identity and essential character, not by the mere presence of glass. The Tribunal treated the articles as composite goods marketed and invoiced as doors and windows, with the aluminium frame forming an integral part of the product. It applied the interpretative approach that a composite article should not be classified as a glass article merely because glass provides a functional attribute. Heading 7610, which covers aluminium doors, windows and their frames, was found to be the proper classification, and Heading 7020 for articles of glass was rejected.

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Issues: Whether bullet proof doors and windows with aluminium frame and glass were classifiable under Heading 7610 as aluminium doors/windows or under Heading 7020 as articles of glass.

Analysis: The goods were commercially known as bullet proof doors/windows and were ordered and invoiced as such. The classification had to be determined by their commercial identity and essential character. The Tribunal noted that the items were not wholly made of glass, the aluminium frame was integral to the goods, and the goods were more appropriately described in trade as doors/windows rather than glass articles. The reliance placed on interpretative rules and case law supported the view that a composite article should not be treated as an article of glass merely because glass imparted a functional attribute. Heading 7610 specifically covered doors, windows and their frames, whereas Heading 7020 was not the proper entry for these goods.

Conclusion: The goods were correctly classifiable under Heading 7610 as aluminium doors/windows. The classification under Heading 7020 was rejected and the appeal was allowed.

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