Tariff classification of impeller rings: specific heading prevails over residuary entry where imported parts have essential character.

A specifically applicable tariff heading prevails over a residuary heading, and imported incomplete goods are classifiable as the finished article if they possess its essential character under Rule 2A of the Customs Tariff Rules. On that basis, impeller rings imported for induced draught fans, being admitted component parts of the fan assembly, were treated as having the character of parts of exhaust fans and blow-airs. They were therefore classifiable under Heading 84.11(4) and not under the residuary Heading 73.33/40, with consequential relief to the importer.

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Issues: Whether impeller rings imported for induced draught fans were classifiable under the residuary Heading 73.33/40 or under Heading 84.11(4) as parts of exhaust fans and blow-airs, applying Rule 2A of the Rules for the Interpretation of the First Schedule to the Customs Tariff Act, 1975.

Analysis: Heading 73.33/40 was residuary in nature, whereas Heading 84.11(4) specifically covered exhaust fans and blow-airs of the relevant sweep. Rule 2A required an incomplete or unfinished article to be treated as the complete article if, as imported, it had the essential character of the finished article. The imported impeller rings were admitted to be component parts of draught fans and, on the material placed, were treated as having the character of the finished component for the fan assembly.

Conclusion: The impeller rings were correctly classifiable under Heading 84.11(4) and not under Heading 73.33/40.

Final Conclusion: The assessment was held to be incorrect, and the importer was entitled to the claimed classification with consequential relief.

Ratio Decidendi: A specifically applicable tariff heading prevails over a residuary heading, and an imported incomplete article is classifiable as the finished article when it possesses the essential character of that article.

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