Interpretative Rule 2(a) inapplicable where imported steel strip remained unfinished and lacked the character of knives or blades.

Imported semi-finished cold rolled, cold drawn carbon steel strip in carburised spiral coil form, intended for manufacture of blades or knives, was not classifiable as knives or cutting blades under Heading 82.06. The goods still required several further manufacturing operations and had not acquired the essential characteristics of finished industrial knives or blades. Interpretative Rule 2(a) was held inapplicable because the materials remained unfinished raw material rather than complete or substantially complete articles. Assertions made before the lower authority were insufficient to show that the goods had already attained the character of knives, so classification under Heading 82.06 failed.

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Issues: Whether the imported semi-finished steel strips were classifiable as knives and cutting blades under Heading 82.06 by applying Interpretative Rule 2(a), or whether they remained raw material/unfinished goods assessable under a different tariff heading.

Analysis: The invoice and bill of entry described the goods as semi-finished cold rolled, cold drawn carbon steel strip in carburised form, in spiral coil form, intended for the manufacture of blades/knives. The record also showed that several further manufacturing operations were still required to convert the goods into knives. On that basis, the goods were found to be far from the stage of finished industrial knives or blades and had not acquired the essential characteristics of the final product. The Tribunal also held that the subsequent assertions made before the lower authority could not be treated as proof that the goods had already attained the character of knives, and the cited precedent on Rule 2(a) was therefore inapplicable.

Conclusion: Interpretative Rule 2(a) was not applicable, and the claim for classification under Heading 82.06 failed.

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