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Issues: Whether additional car seat covers made of leather or textile material are classifiable as parts of seats under Chapter Heading 94.01 or as accessories of motor vehicles under Chapter Heading 87.08.
Analysis: The goods were found to be additional seat covers and not integral parts of the car seats. Chapter Heading 94.01 applies to seats and parts thereof, whereas Chapter Heading 87.08 covers parts and accessories of motor vehicles. Applying the functional and trade understanding of an accessory, the goods were held to be items that add comfort and convenience to the use of car seats without becoming part of the seat structure. The reasoning was supported by the accepted distinction between parts and accessories and by the market character of the goods as seat accessories.
Conclusion: The goods are accessories of car seats and are correctly classifiable under Chapter Heading 87.08, not under Chapter Heading 94.01.
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