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    <description>International Renewable Energy Certificates downloaded electronically were treated as intangible goods because they had utility and were capable of sale, transfer, delivery, storage and possession, but customs duty could not be levied on such electronic imports since the customs law then provided machinery only for tangible imports. Physical import was not mandated under the Customs Act or Customs Tariff Act. Where the certificates were imported in physical form, they were treated as documents of title conferring entitlement, and were classifiable under the residuary entry in Heading 4907, Tariff Item 4907 00 90.</description>
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