Corrosion-resistant valve lining can satisfy tariff classification where the functional portion alone is lined, not only the entire valve.

Tariff Heading 84.61(2) was construed to cover valves lined with corrosion-resistant material in the portion that actually contacts corrosive gas or fluid, not only valves fully lined throughout. The wording was read as extending beyond valves made entirely of corrosion-resisting materials, because limiting the heading to complete lining would render the reference to other lined valves redundant. On that interpretation, valves with only the critical or functional portion lined fell within the heading for customs classification and refund purposes, and the Revenue's appeal failed.

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Issues: Whether valves imported with only the critical or functional portion lined with corrosion-resistant material fall within Tariff Heading 84.61(2) of the Customs Tariff Act, 1975, for the purpose of classification and refund.

Analysis: The tariff description covered not only valves made of corrosion-resisting materials but also other valves lined with rubber or other corrosion-resisting materials. The wording was read as extending to lining of the portion of the valve that actually comes into contact with corrosive gas or fluid, namely the critical or functional portion. An interpretation requiring the entire valve to be lined would make the latter part of the tariff entry redundant, since such cases would already be covered by the opening part of the heading.

Conclusion: The valves were held to fall within the tariff heading even though only the critical portion was lined with corrosion-resistant material, and the Revenue's appeal failed.

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