Master alloy classification denied for finished brass tyre valves; tariff heading held inapplicable.

Finished tyre valves made of brass were not treated as a master alloy under Heading 74/01/02 because a master alloy is an alloying element or additive used in making alloys, not a finished article. The Tribunal accepted the revenue's classification view on the basis that brass construction alone did not convert the valves into master alloy goods, and held that the claimed tariff heading was inappropriate. The classification claim was rejected and the appeal failed.

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Issues: Whether finished tyre valves made of brass were classifiable as master alloy under Heading 74/01/02 of the Customs Tariff, or whether they fell outside that heading and the appeal against the classification order could succeed.

Analysis: Master alloy denotes an alloying element or additive used in the manufacture of alloys and is not itself a finished article. Finished tyre valves cannot be treated as master alloys merely because they are made of brass, which is a copper alloy. The Tribunal therefore accepted the revenue's view that the claimed heading was inappropriate and saw no reason to interfere with the lower appellate order.

Conclusion: The classification claim under Heading 74/01/02 was rejected and the appeal failed.

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