Tariff classification of corrosion resisting valves upheld under the specific heading, not the residuary entry.

Imported tube valves made of copper alloy were held classifiable under Heading 84.61(2) as valves made of corrosion resisting materials, because the tariff description was treated as illustrative rather than confined to the specific metals named. The goods were not excluded merely because they were not lined with rubber, and trade nomenclature could not displace the clear tariff wording. Applying the rule that an article with a reasonable claim to a specific heading should not be forced into a residuary entry, the assessment under the residuary sub-heading was set aside. The valves were also treated as non-return valves, since air flow was one-way and reversal was blocked.

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Issues: Whether the imported tube valves made of copper alloy were classifiable under Heading 84.61(2) as valves made of corrosion resisting materials, or under the residuary sub-heading.

Analysis: The description in Heading 84.61(2) was read as illustrative of the class of corrosion resisting materials and not as limited only to the specific metals named therein. Copper alloy, being corrosion resistant in the relevant context, fell within that description. The fact that the goods were not lined with rubber was held to be irrelevant. Trade nomenclature could not override the clear tariff description, and where an article had a reasonable claim to an enumerated heading it should not be forced into a residuary entry. The valves were also treated as non-return valves because the air flow was one-way and reversal was blocked.

Conclusion: The goods were classifiable under Heading 84.61(2), and the assessee succeeded.

Final Conclusion: The assessment under the residuary heading was set aside and the classification was directed to be made under the specific heading for corrosion resisting valves.

Ratio Decidendi: A tariff description referring to valves made of corrosion resisting materials is not confined to the specific metals named in the illustration and, where goods reasonably answer that description, they must be classified under the specific entry rather than the residuary one.

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