Kreiss Corp. v. United States

69 Cust. Ct. 37, 1972 Cust. Ct. LEXIS 2500
CourtUnited States Customs Court
DecidedAugust 3, 1972
DocketC.D. 4372
StatusPublished
Cited by1 cases

This text of 69 Cust. Ct. 37 (Kreiss Corp. v. United States) is published on Counsel Stack Legal Research, covering United States Customs Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kreiss Corp. v. United States, 69 Cust. Ct. 37, 1972 Cust. Ct. LEXIS 2500 (cusc 1972).

Opinion

Landis, Judge:

The relatively broad issue in these protests, consolidated for trial, is Whether glass vases imported from Japan in 1964 and 1965 are, as plaintiff claims, properly classifiable under TSUS (Tariff Schedules of the United States) item 546.35 as glassware, [38]*38colored prior to solidification., and characterized by random distribution of numerous bubbles, seeds, or stones, throughout the mass of the glass and, therefore, not classifiable, as liquidated by customs, under TSUS item 546.51 as glassware, inter alia, not so colored and not so characterized, throughout the mass of the glass. Customs assessed duty at 50 per centum ad valorem. The duty rate under plaintiff’s claimed TSUS item 546.35 is 25.5 per centum ad valorem.

Classification under TSUS items 546.35 and 546.51 is provided for in schedule 5, part 3, subpart C of the tariff schedules in pertinent context as follows:

Schedule 5. - NoNmetallic MiNerals AND Products
Part 3.-Glass and Glass Products
Subpart C. - Glassware AND ■ Other Glass Products
=:= * * * * * *
Articles chiefly used in the household or elsewhere for preparing, serving, or storing food or beverages, or food or beverage ingredients; smokers’ articles, household articles, and art and ornamental articles, all the foregoing not specially provided for:
Glassware made of glass containing by weight over 24 percent 'lead monoxide:
* * * * t. * *
Glassware, other than the foregoing, decorated with metal flecking, glass pictorial scenes, or glass thread- or ribbon-like effects, any of the foregoing embedded or introduced into the body of the glassware prior to its solidification; millefiori glassware:
* :{: * * % tfc >1:
546.35 Glassware, other than the foregoing, colored prior to solidification, and characterized by random distribution of numerous bubbles, seeds, or stones, throughout the mass of the glass_ 25.5% ad val.
* " * Glassware, other than the foregoing, pressed and toughened (specially tempered), chiefly used for preparing, serving, or storing food or beverages, or rood or beverage ingredients_ * * *
Other glassware:
Valued not over $1 each:
* * * * * * *
546.51 Other 50% ad val.

[39]*39Before reviewing the record, we best set forth the legislative background cited by counsel on both sides, explaining that the above classifications of glassware:

* * * [divide] the glassware into four general categories— categories based on the character of the glass itself: (1) glassware containing over 24 'percent lead oxide; (2) that containing metal flecking; (3) that containing numerous bubbles, seeds or ¿tones throughout the mass of glass; and (4) all other glassware. These four general groups are further broken down into value brackets and in some instances the value brackets themselves are subdivided. The current provisions for these articles are the result of a number of trade-agreement concessions. These concessions have subdivided paragraph_218(f) into a number of confused and overlapping classifications based upon value, type of ware, use, and decoration. The proposed provisions reorganize the existing provisions into an orderly system of mutually exclusive descriptions.1
íjs ¡ft ^
The description of “bubble” glassware (item 546.35) has been clarified. The existing provisions for such glass was originally 'based upon a concession in the bilateral trade agreement with Mexico and covered Mexican bubble glass. Such glassware is characterized by a very substantial number of bubbles, seeds and stones through the mass of the glass. In the proposed language it is believed there is provided a clearer definition of the ware to be covered. The provision for production otherwise than by automatic machine does not furnish a useful distinction and has been eliminated.2

[Additional Explanatory Notes and Background Material.] 3

Item 546.35 - Bubble glass. A question arose as to whether the Commission’s description of bubble glass is a departure from existing practice with respect to the classification of pertain Italian glassware. It is the Commission’s intention and belief that this description will continue the existing tariff treatment as reflected in OIE’s 312/48; 1741/56. The words “numerous” and “haphazard” in the article description and the original explanatory notes were used to convey the idea that the glassware contains no refining materials, deviates from regularity of design and •contains uncontrolled bubbles, cords, seeds, and striae. _
_ Examination of samples of the Italian glassware in question clearly indicated that it is comparable to Mexican bubble glass and would clearly be within the scope of item 546.35.
We are advised that the Italian and Mexican glass are made by the same process. In both cases most of the glass is hand-made, and the bubbles are a natural consequence of impurities in the glass. In both cases there is no control applied to increase or reduce •the number of bubbles in the glass. The number of bubbles will [40]*40vary according to the extent of the impurities- and according to the part of the furnace from which the glass in a particular piece was drawn, i.e., the nearer to the 'bottom the more impurities and the more bubbles. While a given piece of Italian glass may vary from a given piece of Mexican glass as to the number and size of bubbles evident to the naked eye, we know of no way to make any meaningful distinction between the two products in terms of ingredients, production process, general appearance or market served.

On trial at Los Angeles, plaintiff adduced testimony from two witnesses and introduced in evidence five exhibits (exhibits 1 through 5). Defendant introduced two exhibits (exhibits A and B) and called one witness to testify.

It is stipulated that exhibit 1 is a representative sample of the assortment of vases in protest 67/3200, identified on the invoice as item K-932. Exhibit 1 is a vase of reddish-orange color. The lip or rim (which is fluted) and the lower part of the vase reflect a deeper hue of the color that blends lighter in the body of the vase. The base of the vase, which shows as clear uncolored glass, mirrors the cast of the orange color. There are noticeably visible bubbles of assorted sizes in the glass.

The record establishes that the vase involved in protest 65/23967 is the manufacturer’s invoice item K-908. Exhibit 2 is a vase identified as item K-977, not involved in this litigation, which plaintiff’s witness testified was made by the manufacturer of item K-908. The blue color of exhibit 2 blends in the same 'fashion as that described for exhibit 1. The rim is fluted and the clear uncolored base of the vase mirrors the cast of the blue color. There are bubbles in the glass. Defendant, after voir dire

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Cite This Page — Counsel Stack

Bluebook (online)
69 Cust. Ct. 37, 1972 Cust. Ct. LEXIS 2500, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kreiss-corp-v-united-states-cusc-1972.