Specific tariff heading prevails over residuary heading for copper and brass parts used in taps, cocks and valves.

Copper and brass goods used for draining air or fluid were classified as parts of taps, cocks, valves and similar appliances under sub-heading 8481.99, not as other copper articles under sub-heading 7419.99. The goods were treated as components of a specific Chapter 84 appliance because Heading 84.81 covers taps, cocks, valves and similar appliances and their parts. Section Note 2(a) of Section XVI required classification in the heading where the goods are themselves included, leaving no scope to treat them as parts of radiators. The residuary nature of Heading 74.19 could not override the specific heading.

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Issues: Whether the copper and brass products manufactured by the appellant were correctly classifiable under sub-heading 8481.99 as parts of taps, cocks, valves and similar appliances, or under sub-heading 7419.99 as other articles of copper/brass.

Analysis: The goods were found to be used for draining air or fluid and were treated as components of tap, cock, valve or similar appliances rather than as parts of radiators. The radiators themselves were not shown to be central-heating radiators of iron or steel, and the appellant could not establish the precise end-use or nature of the radiators for which the goods were said to be parts. Heading 84.81 specifically covered taps, cocks, valves and similar appliances, and the relevant parts thereof were classifiable under sub-heading 8481.99. By contrast, Heading 74.19 was a residuary entry for other articles of copper. Under Section Note 2(a) of Section XVI, goods included in a heading of Chapter 84 are to be classified in that heading, leaving no scope to treat them as parts of radiators. The goods were also not parts of general use so as to take them of the specific heading.

Conclusion: The classification under sub-heading 8481.99 was upheld and the rival claim under sub-heading 7419.99 was rejected.

Ratio Decidendi: Where goods are specifically covered by a tariff heading as parts of a particular appliance, they must be classified under that specific heading rather than under a residuary heading for general articles, and Section Note 2(a) of Section XVI requires classification in the heading in which the goods are themselves included.

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