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Issues: Whether the proposed import goods, namely PS moulding, PS wall panel, PS L profile, PS wall panel sheet, PVC panel foam, PVC sheet UV, PVC panel, PVC vinyl sheet, PVC panel WPC mould, PVC wall panel and PU wall panel, are classifiable under heading 3921 of the Customs Tariff Act, 1975 as plates, sheets, film, foil and strip of plastics, or under heading 3925 as builders' ware of plastics.
Analysis: Classification under the Customs Tariff is to be determined in accordance with Rule 1 of the General Rules for the Interpretation of the First Schedule to the Customs Tariff Act, 1975, read with the relevant Section and Chapter Notes. Heading 3921 covers cellular, reinforced, laminated, supported or similarly combined plastic plates and sheets, including products that are surface-worked, cut into rectangles or squares, and not further worked. Heading 3925 is a residual heading confined to the articles specifically listed in Chapter Note 11 to Chapter 39, including structural elements, ornamental architectural features and fittings intended for permanent installation. The goods on record were found to include plain rectangular plastic sheets as well as moulded or profiled wall panels with interlocking edges. On the facts accepted in the ruling, these products retained the essential character of plates or sheets of plastics. The interlocking or tongue-and-groove edge profile was treated as an in-line extrusion feature and not as further working of the kind that takes the goods out of heading 3921. The products were also held not to answer the description of structural elements, since they were lightweight decorative overlays and not load-bearing or framework components of a building. Likewise, they were not treated as ornamental architectural features within Chapter Note 11(h), because the examples in that note denote specialised architectural components rather than decorative wall coverings.
Conclusion: The goods are classifiable under heading 3921 and not under heading 3925; the classification claim under sub-headings 39211100, 39211200 and 39211390 is accepted, subject to verification of actual composition and structure.
Ratio Decidendi: Plastic sheets or panels that remain identifiable as plates or sheets of plastics, and are not further worked into distinct building articles falling within the closed list of Chapter Note 11 to Chapter 39, continue to fall under heading 3921 even if they are decorative and fitted with integrated edge profiles for installation.