Tariff classification of dies: specific heading for interchangeable tools prevailed over machine-tool parts heading.

Dies and tungsten carbide heading pellets used in a cold forging machine were held to be interchangeable tools, not parts or accessories of machine tools. Heading 82.02 specifically covers dies for drawing or extruding metal, while Heading 84.66 applies only to parts and accessories suitable for use solely or principally with machine tools of Headings 84.56 to 84.65. As the goods functioned as external working tools and no material showed they were machine-tool components, classification under Heading 82.02 / sub-heading 8202.10 was upheld and sub-heading 8466.00 was rejected.

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Issues: Whether the disputed dies and tungsten carbide heading pellets were classifiable under sub-heading 8466.00 as parts and accessories of machine tools, or under Heading 82.02 / sub-heading 8202.10 as interchangeable tools including dies for drawing or extruding metal.

Analysis: The goods were found to be used in a cold forging machine as dies held by a die holder for shaping metal by pressure. Heading 84.66 applies to parts and accessories suitable for use solely or principally with machine tools of Headings 84.56 to 84.65, whereas the disputed goods were not shown to be machine-tool parts. Heading 82.02 specifically includes interchangeable tools and expressly covers dies for drawing or extruding metal. No material was placed to disturb the appellate finding that the dies were external working tools and not components of the machine.

Conclusion: The goods were correctly classified under Heading 82.02 / sub-heading 8202.10 and not under sub-heading 8466.00, and the classification adopted against the assessee was upheld.

Final Conclusion: The appeal failed on the question of tariff classification and the departmental classification was sustained.

Ratio Decidendi: Dies used as working tools in a machine, when expressly covered by a specific tariff entry, are classifiable under that specific entry and not as parts or accessories of machine tools under a general residual heading.

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