Classification of base-metal springs: imported springs remained under Chapter 73 because they were not assembled machinery parts.

Imported spring clocks were held classifiable under Tariff Heading 7320.90, not under Tariff Heading 8448.49 as machinery parts, because iron and steel springs other than clock or watch springs fall within Chapter 73 as articles of general use. The Section XVI and Section XV notes exclude such base-metal springs from Chapter 84 parts treatment unless they are imported in an assembled form that answers the description of excluded machinery parts. As the goods were imported as springs, not as assembled machinery parts, the Chapter 73 classification was sustained and the alternative claim under Chapter 84 was rejected.

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Issues: Whether the imported spring clocks were classifiable under Tariff Heading 8448.49 as parts of machinery or under Tariff Heading 7320.90 as iron and steel springs.

Analysis: Tariff Heading 73.20 covers iron and steel springs other than clock and watch springs, and the HSN notes indicate that springs of all types are covered under that heading. Under Section Note XVI and Note 2 to Section XV, springs and leaves for springs of base metal other than clock or watch springs are treated as articles of general use and are excluded from the scope of parts of machinery in Chapter 84. The exclusion relied upon by the appellant applies only where springs are imported in assembled form and answer the description of the excluded machinery parts. The goods imported were springs as such and not assembled machinery parts.

Conclusion: The goods were correctly classifiable under Tariff Heading 7320.90, and the claim for classification under Tariff Heading 8448.49 was rejected.

Final Conclusion: The appeal failed, and the assessment under Chapter 73 was sustained.

Ratio Decidendi: Springs of base metal other than clock or watch springs are articles of general use and remain classifiable under Chapter 73 unless imported in an assembled form that specifically brings them within an exclusion for machinery parts.

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