Specialised boiler parts classification turns on ceramic lining and exclusive end use, placing lined bends and elbows under Chapter 84.

Ceramic lined bends and ceramic lined elbows used in industrial boilers were treated as specialised boiler parts after the ceramic lining gave them a distinct character and exclusive end use. That specialised character took them outside the exclusion for parts of general use under Note 1(g) of Section XVI, so they were not classifiable as ordinary iron and steel articles under Chapter 73. They were classified as parts of boilers under Chapter 84 because the same reasoning applied to similarly lined items and their end use in boilers was decisive.

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Issues: Whether ceramic lined bends and ceramic lined elbows, after lining with ceramic tiles and intended for use in industrial boilers, were classifiable as parts of boilers under Chapter 84 or as parts of general use under Chapter 73.

Analysis: The decisive question was whether the lining process had given the items a distinct character as specialised boiler parts so that the exclusion for parts of general use under Note 1(g) of Section XVI would no longer apply. The items had undergone ceramic lining and were admitted to be used in boilers. The same treatment had already led to classification of similar lined items under Chapter 84, and the reasoning applied to those items was equally applicable here. Once the goods acquired special characteristics for boiler use, they could not be treated as ordinary articles of iron and steel under Chapter 73.

Conclusion: The ceramic lined bends and ceramic lined elbows were held to be parts of boilers classifiable under Chapter 84, and not parts of general use under Chapter 73.

Ratio Decidendi: Where base metal items undergo a process that gives them a specialised character and exclusive use as machinery parts, they cease to be parts of general use and must be classified according to their specialised end use.

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