Tariff classification of paper filter elements turns on heading notes, not commercial use as machine parts.

Filter paper packs and filter elements made from paper were classified by reference to the tariff headings and the relevant Section and Chapter Notes, not by their use in machinery. The exclusionary HSN note under Heading 8421 controlled because paper-based filter elements were specifically treated according to constituent material and were not covered as machinery parts. Commercial parlance, part numbers, replacement status, and use in filter machines could not override the statutory interpretation rules. The goods were therefore classifiable under Heading 4823 as paper articles, and the departmental classification was upheld.

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Issues: Whether the goods described as filter paper packs / filter elements were classifiable under Heading 8421 as parts of filtering machinery, or under Heading 4823 as paper articles; and whether commercial parlance or the fact that the goods were used as machine parts could control classification.

Analysis: The goods were found to be manufactured from paper, cut to size and further processed into filtering elements. The applicable classification had to be determined by the terms of the headings read with the relevant Section and Chapter Notes under the tariff interpretation rules. The exclusionary note in the HSN materials under Heading 8421 was treated as controlling, because filter elements made of paper were specifically indicated to fall according to their constituent material, and paper filter blocks were not covered as machinery parts. Commercial trade parlance was held to be a non-statutory aid that could not prevail over the statutory rules of interpretation. The fact that the goods were used in filter machines, had part numbers, or were supplied as replacement parts did not alter their identity as paper-based filter elements.

Conclusion: The goods were not classifiable under Heading 8421 and were correctly classifiable under Heading 4823. The classification adopted by the department was upheld.

Ratio Decidendi: For tariff classification, the heading terms and the applicable Section and Chapter Notes govern, and where the tariff and HSN notes exclude an article by reference to its constituent material, its use as a machine part or its commercial description cannot override that statutory classification.

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