Specific tariff description prevails over end-use in customs classification, while timers failed the clock-movement test.

Specific tariff description prevails over end-use in customs classification. Springs used in washing machines were held classifiable under Heading 73.20 as springs of iron or steel because Section XVI Note 2 did not displace the specific heading, even though they were intended for machinery use. Timers were not classifiable under Heading 91.07 because that entry covers time switches with clock or watch movement or synchronous motor, and the goods were not shown to meet that description. The article therefore states the classification principle that tariff headings must be applied by the wording of the entry and the relevant section and chapter notes.

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Issues: (i) Whether Springs used in washing machines were classifiable under Heading No. 73.20 or under sub-heading 8450.90 of the Customs Tariff Act; (ii) Whether Timers were classifiable under Heading No. 91.07 or under sub-heading 8450.90 of the Customs Tariff Act.

Issue (i): Whether Springs used in washing machines were classifiable under Heading No. 73.20 or under sub-heading 8450.90 of the Customs Tariff Act.

Analysis: Note 2 of Section XVI provides that parts which are goods included in any of the headings of Chapters 84 or 85 are to be classified in their respective headings. Springs were specifically described in Heading No. 73.20 as springs and leaves for springs of iron or steel. The fact that they were intended for washing machines did not displace the specific tariff description.

Conclusion: The Springs were classifiable under Heading No. 73.20 and not under sub-heading 8450.90. The finding is against the assessee on this issue.

Issue (ii): Whether Timers were classifiable under Heading No. 91.07 or under sub-heading 8450.90 of the Customs Tariff Act.

Analysis: Heading No. 91.07 covers time switches with clock or watch movement or with synchronous motor. The goods were described only as Timers and were neither shown to have clock movement nor to fall within the meaning of watch movements under Chapter Note 3 of Chapter 91. On the available description, they did not answer the tariff entry relied on by the Revenue.

Conclusion: The Timers were not classifiable under Heading No. 91.07 and were more appropriately placed under sub-heading 8450.90. The finding is in favour of the assessee on this issue.

Final Conclusion: The appeal succeeded only in relation to the Timers and failed in relation to the Springs, resulting in a partial allowance of the appeal on classification.

Ratio Decidendi: Where goods are specifically described in a tariff heading, that specific description prevails over their end-use or association with a particular machine, and classification must be determined by the tariff entry read with the relevant section and chapter notes.

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