Composite furniture classification favoured the later tariff heading where a dual-desk was neither purely a seat nor purely a desk.

A dual-desk made of wood, combining a two-person bench and a two-person desk, was treated as a composite product for tariff classification. Because it was neither purely a seat nor purely a desk, Tariff Headings 94.01 and 94.03 were both considered applicable. Classification was resolved by applying clause (c) of Rule 3 of the Rules for Interpreting the Central Excise Tariff, under which the heading appearing later in numerical order prevails when the competing headings cannot otherwise be distinguished. The goods were therefore classified under Tariff Heading 94.03 rather than Tariff Heading 94.01.

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Issues: Whether a dual-desk made of wood, consisting of seating arrangement and desk joined together, was classifiable under Tariff Heading 94.03 as furniture or under Tariff Heading 94.01 as seats.

Analysis: The goods were found to be a composite product comprising both a bench for two persons and a desk for two persons. Since the product was neither purely a seat nor purely a desk, both Tariff Headings 94.01 and 94.03 were treated as equally applicable. The determining factor was the application of clause (c) of Rule 3 of the Rules for Interpreting the Central Excise Tariff, under which the heading occurring later is preferred when classification cannot be resolved under the earlier clauses.

Conclusion: The goods were held classifiable under Tariff Heading 94.03 and not under Tariff Heading 94.01.

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