Tariff classification of hairspring with collet: fixing attachment did not change its status as a spring under Heading 73.20.

Imported hairsprings with a collet remained classifiable as springs under Heading 73.20 of the Customs Tariff Act, 1975 because the collet functioned only as a fixing attachment and did not convert the item into an instrument part or assembly. The tariff scheme treats springs other than clock or watch springs as parts of general use under Section XV, and that specific treatment prevailed over Chapter 90 classification for identifiable parts of instruments. Goods described as hairspring with collet and used in pressure gauges were therefore classified under Heading 73.20, not Heading 90.26.

---

---

Issues: Whether the imported hairspring with collet was classifiable as springs under Heading 73.20 of the Customs Tariff Act, 1975 as a part of general use, or as parts of pressure gauges under Heading 90.26.

Analysis: The decisive question was whether the presence of a collet altered the nature of the imported item. The record showed that the goods were described as a hair spring with collet and were used in pressure gauges. The relevant tariff scheme treats springs, other than clock or watch springs, as parts of general use under Note 2(b) to Section XV, and Heading 73.20 covers springs and leaves of springs of iron or steel. The additional fitting of a collet was treated as a means of fixing or attaching the spring and not as converting a single spring into an assembly or sub-assembly. The exclusion for identifiable parts of instruments under Chapter 90 was held not to override the specific treatment of springs under Section XV.

Conclusion: The imported goods were classifiable under Heading 73.20 of the Customs Tariff Act, 1975 and not under Heading 90.26; the departmental classification was upheld.

Ratio Decidendi: Springs other than clock or watch springs remain parts of general use under Section XV, and the addition of fittings such as a collet does not change their tariff classification into a part of an instrument or assembly.

---