Principal use classification governed imported stapling machines, confirming office-machine treatment and maintaining countervailing duty.

Imported stapling machines were analysed under competing Customs Tariff headings by reference to their principal use and essential function. The catalogue evidence showed the goods were marketed mainly as staplers for papers, with tacking and pinning only ancillary, and occasional industrial descriptions did not displace their predominant office character. There was no material to classify them as book-binding or paperboard-making machinery, and the presence of secondary functions did not take them outside the scope of office machines. Applying the principle that a multi-purpose machine is classified by its principal purpose, the machines fell under Heading 84.51/55, and the consequential countervailing duty treatment under Item 33D was maintained.

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Issues: Whether imported stapling machines were classifiable as office machines under Heading 84.51/55 of the Customs Tariff Act, or fell under Heading 84.32 or 84.33, and whether the consequential countervailing duty under Item 33D of the Central Excise Tariff was maintainable.

Analysis: The competing headings had to be tested on the basis of the goods' principal use and essential function. The catalogue material showed that the machines were marketed principally as staplers for papers, with tacking and pinning only as ancillary or possible uses. The description of industrial use in some catalogues did not displace the predominant office character of the imported machines. The Court further found no material to support classification under book-binding machinery or paperboard-making machinery, and the record did not establish that the stapling pins or secondary functions took the machines outside the scope of office machines. Applying the chapter note that a multi-purpose machine is classified according to its principal purpose, the relevant tariff treatment followed the primary stapling function.

Conclusion: The imported stapling machines were held to be office machines classifiable under Heading 84.51/55, not under Headings 84.32 or 84.33, and the countervailing duty assessment under Item 33D was upheld.

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