Classification of grinding steel balls as parts of grinding machinery under Heading 84.56, not general steel goods

Imported grinding steel balls specially used in a cement plant's ball mill and not usable independently were treated as integral parts of the grinding mill, so they fell within Section XVI, Note 2(b), covering parts suitable solely or principally for use with a particular machine. Heading 84.56, which covers machinery for crushing and grinding mineral substances together with its parts, was therefore applied, and Heading 73.40 was rejected. The Tribunal also held that section notes and chapter notes prevail over explanatory notes, so the explanatory note to Heading 73.40 could not override the tariff structure under the Customs Tariff Act, 1975.

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Issues: Classification of imported grinding steel balls under Heading 73.40 of the Customs Tariff Act, 1975 or under Heading 84.56 as parts of grinding machinery.

Analysis: The imported steel balls were found to be specially used in the cement plant's ball mill and not usable by themselves. On that basis, they were treated as integral parts of the grinding mill. The Tribunal held that Section XVI, including Note 2(b), governs parts suitable solely or principally for use with a particular machine, and that Heading 84.56 covers machinery for crushing and grinding mineral substances together with its parts. It further held that section notes and chapter notes prevail over explanatory notes, so the explanatory note to Heading 73.40 could not displace the tariff scheme under the Customs Tariff Act, 1975.

Conclusion: The goods were correctly classifiable under Heading 84.56 of the Customs Tariff Act, 1975, and not under Heading 73.40.

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