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Issues: Whether the imported kettle components were classifiable as electric kettle under Rule 2(a) of the General Rules for the Interpretation of the Import Tariff, or only as parts of an electric kettle.
Analysis: Rule 2(a) treats incomplete or unfinished articles, and also articles presented unassembled or disassembled, as the complete or finished article if, as presented, they have the essential character of that article. The imported goods comprised the principal functional components of an electric kettle, including the kettle body, heating element, lid and thermostat. The absence of some additional parts procured domestically, such as wire, plug, screw and sensor, did not alter the essential character of the goods, since those items were treated as minor or supplementary features and the thermostat itself performed the temperature-sensing function. The goods were therefore an incomplete kettle having the essential character of a complete kettle.
Conclusion: The imported goods were correctly classifiable as electric kettle under Rule 2(a), and not merely as parts of an electric kettle.
Final Conclusion: The classification adopted by the original authority was restored and the Revenue succeeded in the appeal.
Ratio Decidendi: For classification under Rule 2(a), incomplete or unassembled goods are to be treated as the finished article when they possess its essential character, even if some ancillary parts are procured separately.