Infant chairs without amusement features are classifiable as furniture, not toys, in tariff classification.

Infant rocking chairs and baby chairs were held classifiable as chairs and furniture under Heading 9401 because they were specially sized for infants and lacked any distinct amusement feature that would make them toys. The tariff analysis relied on the goods' essential character and treated the HSN explanatory notes as persuasive guidance, noting that those notes specifically place infant's chairs within furniture. On that basis, the classification under Chapter 94 was affirmed and Heading 9503 for toys was rejected.

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Issues: Whether rocking chairs and baby chairs manufactured for infants were classifiable under Heading 9503 as toys, or under Heading 9401 as chairs and furniture.

Analysis: The goods were chairs of a size specially intended for infants. There was no evidence that they possessed any device capable of providing amusement or that they were designed primarily to produce amusement so as to qualify as toys. The HSN explanatory notes, though not binding, had persuasive value and specifically treated infant's chairs as furniture. On that basis, the goods were appropriately regarded as chairs falling under Chapter 94 rather than toys under Chapter 95.

Conclusion: The goods were correctly classified under Heading 9401 as chairs and furniture, and not under Heading 9503 as toys.

Final Conclusion: The classification adopted by the lower authorities was upheld and the appeal failed.

Ratio Decidendi: Goods intended as infant chairs, absent a distinct amusement feature, are classifiable as furniture rather than toys; HSN explanatory notes may be used as persuasive guidance in tariff classification.

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