Classification of radiator parts follows their principal use with Chapter 84 machinery, not motor vehicle headings.

Radiator cores and radiator assemblies specially used with machinery under Headings 84.25 to 84.30 were treated as parts suitable for use solely or principally with that machinery and not as motor vehicle parts. Section XVII Note 2(e) excludes such machine parts from that section, while Section XVI Note 1K excludes articles of Section XVII from Section XVI. As the goods were not interchangeable with or fit for motor vehicles, classification under Heading 84.31 was upheld and classification under Heading 87.08 for motor vehicle radiators was rejected.

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Issues: Whether radiator cores and radiator assemblies used with machinery under Headings 84.25 to 84.30 were correctly classifiable under Heading 84.31, and whether radiators meant for motor vehicles were classifiable under Heading 87.08.

Analysis: Note 2(e) to Section XVII excludes from that Section parts and accessories of machines and apparatus falling under Heading Nos. 84.01 to 84.79 and their parts. Note 1K to Section XVI similarly excludes articles of Section XVII from Section XVI. The goods in question were found to be specially used with machinery falling under Headings 84.25 to 84.30 and not interchangeable with or fit for motor vehicles. On that basis, the goods were treated as parts suitable for use solely or principally with the machinery concerned and not as motor vehicle parts.

Conclusion: The classification under Heading 84.31 was upheld and the Revenue's claim for classification of all radiators and radiator cores under Heading 87.08 was rejected.

Ratio Decidendi: Where goods are specially suitable for use solely or principally with machinery covered by Chapter 84 and are excluded from Section XVII by the section notes, they are classifiable under the appropriate machinery heading rather than as motor vehicle parts.

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