Tariff classification of radiator parts: machine-specific use excluded motor vehicle classification and placed goods under Heading 84.31.

Radiator cores and radiator assemblies used solely or primarily with machinery under Headings 84.25 to 84.30 were classified as machine parts under Heading 84.31 rather than as motor vehicle parts under Heading 87.08. The tariff notes controlled the classification: Note 2(e) of Section XVII excluded parts and accessories relating to machines of Heading Nos. 84.01 to 84.79, and Note 1K of Section XVI further excluded articles of Section XVII. Because the goods were not interchangeable with, or fit for, motor vehicles, the exclusion from Section XVII applied and the Revenue's appeal failed.

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Issues: Whether radiator cores and radiator assemblies, when used solely or primarily with machinery falling under Headings 84.25 to 84.30, are classifiable under Heading 84.31 or under Heading 87.08.

Analysis: The relevant tariff notes were applied to determine the proper classification. Note 2(e) of Section XVII excludes from that Section parts and accessories that relate to machines and apparatus of Heading Nos. 84.01 to 84.79, while Note 1K of Section XVI excludes articles of Section XVII. The goods in question were found to be solely or primarily used with machinery under Headings 84.25 to 84.30 and not interchangeable with, or fit for, motor vehicles. On that basis, the exclusion in Section XVII operated against classification under Heading 87.08.

Conclusion: The radiator cores and radiator assemblies were correctly classifiable under Heading 84.31 and not under Heading 87.08; the Revenue's appeal failed.

Ratio Decidendi: Goods that are solely or principally usable with machinery of Headings 84.25 to 84.30 are classifiable according to the tariff notes governing machine parts, and are excluded from classification as motor vehicle parts under Section XVII.

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