Customs classification of reflex gauge glasses treated as parts of liquid level gauges, not glass articles.

Reflex gauge glasses imported for use in liquid level gauges were treated as functional components of those gauges, so they fell under Heading 90.29 as parts or accessories of level gauges. Heading 90.24 covers level gauges themselves, and the analysis accepted that parts of such gauges are classified within Heading 90.29 rather than as separate glass articles under Heading 70.21. The reasoning rejected the Chapter 70 approach because the goods were not considered in isolation as glass products, but by their essential role in liquid level gauge assemblies. On that basis, the classification under Heading 90.29 was affirmed in favour of the assessee.

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Issues: Whether reflex gauge glasses imported for use in liquid level gauges were classifiable under Heading 90.29 of the Customs Tariff as parts or accessories of level gauges, or under Heading 70.21 as glass articles.

Analysis: The imported goods were shown by the material on record to be important components of liquid level gauges. Heading 90.24 specifically covers level gauges, and parts of such gauges fall within Heading 90.29. The reliance on Heading 70.21 was not accepted because the goods were not treated merely as glass articles in isolation, but as functional parts of liquid level gauges. The earlier view based on Chapter 70 and the cited precedent was found not applicable on the facts, since the present dispute turned on the specific heading for level gauges and their parts.

Conclusion: The reflex gauge glasses were correctly classifiable under Heading 90.29 of the Customs Tariff, in favour of the assessee.

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