Classification of fire-resistant filing cabinet turns on commercial identity and essential safe features, not fire resistance alone.

A fire-resistant filing cabinet was held not to satisfy the essential characteristics of an armoured or reinforced safe because its construction, plate thickness, and trade recognition did not show drill-proof or burglary-resistant features. The article was therefore classified according to its true commercial identity as a filing cabinet rather than as a safe, with classification under Tariff Item 8304.00 instead of Tariff Item 8303.00.

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Issues: Whether the fire resistant filing cabinet was classifiable under Tariff Item 8303.00 as armoured or reinforced safes or under Tariff Item 8304.00 as filing cabinets.

Analysis: The product was compared with the tariff descriptions and with the earlier precedent dealing with a similar fire-safe record cabinet. The decisive factor was the nature and description of the article, its construction, plate thickness, lack of drill-proof or burglary-resistant features, and its recognition in trade. On those features, it fell far short of the minimum requirements of a safe and was not shown to be different from the article earlier considered in the cited precedent.

Conclusion: The fire resistant filing cabinet was not classifiable as a safe under Tariff Item 8303.00 and was correctly classifiable as a filing cabinet under Tariff Item 8304.00 in favour of the assessee.

Ratio Decidendi: Where an article, judged by its structure, strength, and trade recognition, does not satisfy the essential characteristics of a safe, it must be classified according to its true commercial identity as a filing cabinet rather than as a reinforced safe.

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