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Issues: Whether wooden segments manufactured to particular shapes and sizes, and used in the manufacture of toys, were classifiable as parts of toys under Heading 9503.00 rather than as other articles of wood under Heading 4410.90.
Analysis: The goods were manufactured to customer-specific shapes and dimensions and were used in the manufacture of toys. The notes filed with the classification list showed that the articles were not mere generic wooden profiles but were specially shaped components intended for use in toy manufacture. The burden lay on the Revenue to establish the claimed classification, and that burden was discharged on the facts. Where a specific tariff entry is available, recourse cannot be had to a more general heading. The relevant tariff principle also permitted parts and accessories suitable for use solely or principally with articles of Chapter 95 to be classified with those articles.
Conclusion: The wooden segments were correctly classifiable under Heading 9503.00 as parts of toys, and the Revenue's classification was upheld.
Ratio Decidendi: Goods specially shaped and suitable for sole or principal use with articles of a particular tariff heading are to be classified under the specific entry covering those articles, rather than under a more general residual heading.