Tariff classification of stainless steel circles as sheets upheld under Chapter Note 1(n), with no diameter limit applied.

Chapter Note 1(n) to Chapter 73 governs classification of non-rectangular sheets or plates, and stainless steel circles were treated as sheets for tariff purposes under Heading 73.15(2). The argument that circles below 500 mm diameter should be excluded was rejected because the Chapter Note prescribes no dimensional limit for non-rectangular shapes. The tariff heading had to be read with the chapter note, and the prior decisions cited were treated as directly applicable. Stainless steel circles were therefore correctly classified under Tariff Heading 73.15(2).

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Issues: Whether stainless steel circles are classifiable as sheets under Tariff Heading 73.15(2) in view of Chapter Note 1(n) to Chapter 73 of the Customs Tariff Act, 1975.

Analysis: The classification turned on the effect of Chapter Note 1(n), which treats non-rectangular sheets or plates as falling within Heading 73.13 and, consequently, supports classification of stainless steel circles as sheets for tariff purposes. The attempt to distinguish the matter on the basis that the circles were below 500 mm in diameter was rejected, as the Chapter Note does not prescribe any dimension for non-rectangular shapes. The interpretative scheme requires the tariff heading to be read with the chapter note, and the prior judicial decisions relied upon were held to be directly applicable.

Conclusion: Stainless steel circles were correctly classified under Tariff Heading 73.15(2), and the challenge to the assessment failed.

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