Tariff classification of tungsten carbide drills as tools, not machinery parts, turns on commercial meaning and chapter notes.

Imported tungsten carbide twist drills were examined for tariff classification between Heading 82.07 as tools and Heading 98.06 as parts of machinery. Chapter 98 applies only where the goods satisfy its specific conditions, including being parts of machinery, equipment, appliances, instruments or articles covered by the relevant chapters. On the facts, the drills were separate tools, not integral components or constituents of drilling machines, and were ordinarily sold and used independently. Applying popular and commercial meaning, supported by the HSN notes, drills were treated as drilling tools. The goods were therefore classifiable under Heading 82.07 and not as machinery parts under Heading 98.06.

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Issues: Whether the imported tungsten carbide twist drills were classifiable under Heading 82.07 as tools, or under Heading 98.06 as parts of machinery falling under Chapter 84.

Analysis: The classification turned on the interaction between the tariff headings, the Section and Chapter Notes, and the interpretative rules. Note 1 to Chapter 98 gives that chapter overriding application to goods satisfying its conditions even if they are covered by a more specific heading elsewhere. However, the goods had to be shown to be parts of machinery, equipment, appliances, instruments, or articles of the specified chapters. On the facts, the drills were not integral parts or constituents of drilling machines; they were separate tools ordinarily sold and used independently, with the choice of tool depending on the work to be done. In tariff classification, goods are to be understood in their popular and commercial sense, and the HSN notes also treated drills as tools for drilling.

Conclusion: The imported drills were classifiable as tools under Heading 82.07 and not as parts of machinery under Heading 98.06.

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