Printed aptitude test booklets classified as printed books, with the specific tariff entry prevailing over stationery

Printed aptitude test booklets were treated as educational printed material with a specific use, not as ordinary stationery. Because they consisted of connected printed sheets intended to function as complete units, they fell within Tariff Item 49.01 covering printed books, booklets, brochures, pamphlets and leaflets. Tariff Item 48.01/21(1) was regarded as a more general provision for paper, paperboard and stationery, so the specific printed-matter entry prevailed over the general stationery entry. The classification adopted by the Department was rejected and the assessee succeeded.

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Issues: Whether printed aptitude test booklets were classifiable as printed books, booklets, brochures, pamphlets and leaflets under Tariff Item 49.01, or as stationery under Tariff Item 48.01/21(1).

Analysis: The imported material was examined along with the accompanying literature and found to be educational printed material designed for aptitude testing. The booklets were not mere stationery, because they formed a connected series of printed sheets with a specific educational purpose and were intended to be used as complete units. Tariff Item 48.01/21 was held to be of a general nature covering paper, paperboard and stationery, whereas Tariff Item 49.01 specifically covered printed books and booklets. The rule that a specific description must prevail over a general one supported classification under Tariff Item 49.01. The prior view that books may be in sheet form also reinforced this conclusion.

Conclusion: The goods were classifiable under Tariff Item 49.01 as printed books and not under Tariff Item 48.01/21(1); the classification adopted by the Department was and the assessee succeeded.

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