Classification of filter elements as parts, not complete filters, turned on their dependence on a housing for filtration.

Filter elements were held to be parts, not complete filtering or purifying machinery, because heading 8421.10 applies only where the goods can perform the filtering function by themselves. The evidence showed the elements had to be fitted into a housing or other appliance before filtration could occur, and the assessee did not establish manufacture of oil filters for internal combustion engines. HSN notes relied on by the assessee instead indicated that oil filters contain filtering elements as components. On that basis, the goods were correctly classified under sub-heading 8421.90 as parts, and the appeals were rejected.

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Issues: Whether the filter elements manufactured by the assessee were classifiable as filtering or purifying machinery and apparatus under sub-heading 8421.10, or as parts under sub-heading 8421.90 of the Central Excise Tariff.

Analysis: The product was found to be only a filtering element and not a complete filter machinery or apparatus. Classification under heading 8421.10 required the goods to be capable of performing the filtering function as such, whereas the evidence showed that the product had to be fitted into a housing or other appliance before filtration could occur. The assessee did not establish that it manufactured oil filters for internal combustion engines; the materials and HSN notes relied upon instead indicated that oil filters contain filtering elements as components. On that basis, the goods were treated as parts rather than complete filters.

Conclusion: The filter elements were not classifiable under sub-heading 8421.10 and were correctly classifiable under sub-heading 8421.90; the appeals were rejected.

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