Supermarket Systems, U.S., Inc. v. United States

13 Ct. Int'l Trade 907
CourtUnited States Court of International Trade
DecidedOctober 27, 1989
DocketCourt No. 86-10-01343
StatusPublished

This text of 13 Ct. Int'l Trade 907 (Supermarket Systems, U.S., Inc. v. United States) is published on Counsel Stack Legal Research, covering United States Court of International Trade primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Supermarket Systems, U.S., Inc. v. United States, 13 Ct. Int'l Trade 907 (cit 1989).

Opinion

Opinion

Carman, Judge:

Plaintiff Supermarket Systems, U.S., Inc. contests the denial by the United States Customs Service (Customs) of a protest filed under sections 514 and 515 of the Tariff Act of 1930, as amended, 19 U.S.C. §§ 1514, 1515 (1982 & Supp. V 1987). The protest challenged the classification of plaintiffs imported merchandise. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1581(a) (1982).

On the basis of the evidence presented at trial, the arguments of the parties and all other papers and proceedings had herein this Court determines that Customs erroneously classified the merchandise in issue under the Tariff Schedules of the United States (TSUS) item 653.00 for other structures and parts of structures and holds that the appropriate classification is under TSUS item 657.25 the basket provision for articles of iron or steel, not coated or plated with precious metal.

Background

This case concerns the classification of Openmatic automatic entry gates which were imported from France to the port of Chicago, Illinois on July 31, 1985. Openmatics are steel devices equipped with a gate arm and an alarm. They are placed at the entrance way of public buildings, such as retail stores, libraries and airports to prevent pilferage by controlling ingress and egress.

The devices consist of two railings, each of which are created by two columns supporting a horizontal bar. The two railings which are not attached to each other, form a corridor which leads towards a cylindrical steel housing. This housing contains the working and power mechanism and a pivoting gate arm. The gate arm is normally equipped with signs that say "Welcome” on the entrance side, and "Emergency Exit Only” on the exit side. One of the columns supports a railing containing a photo-electric cell. An infra-red beam, generated by the photo-electric cell, is focused on a reflector. When a person approaches the entry gate the beam is broken, the motor switched on, and the gate arm swings open. When the gate arm is moved approximately six inches in the exit direction, an [908]*908alarm is activated, alerting establishment personnel to unauthorized exits.

Customs classified the merchandise under TSUS 653.00 as "other structures and parts of structures * * * of iron or steel * * * Other,” and assessed a duty of 6.7% ad valorem. Plaintiff contests this classification and asserts the merchandise is more specifically described under TSUS item 685.70 as a "other sound or visual signalling apparatus * * * electrical, and parts thereof * * * Other * * *,” assessed at a rate of 3 percent ad valorem. Alternatively, plaintiff claims that the merchandise should be classified under TSUS item 683.32 "other electro-mechanical appliances * * * with self contained electric motors, of the types used in the household, hotels, restaurants, offices, schools or hospitals * * * Other,” at a rate of 4.7 percent ad valorem, or under TSUS item 727.70 "furniture * * * Other * * at a rate of 5.5 percent ad valorem.

If Customs’ classification of the Openmatic as a structure under item 653.00, TSUS, is overruled, Customs asserts as an alternative, that the merchandise should be classified under item 657.25 "articles of iron or steel, not coated or plated with precious metal * * * Other * * *,” at a rate of 6.7 percent ad valorem.

Plaintiff seeks relief in the form of reclassification of the Openmatic under any of its alternatives and a refund of all excess customs duties.

Customs seeks the affirmance of its original classification under 653.00, TSUS or in the alternative classification under the basket provision, TSUS item 657.25.

The following are the pertinent provisions of the tariff schedule.

Classified under:

Schedule 6, Part 3, Subpart F, item 653.00 which provides in pertinent part:

Hangars and other buildings, bridges, bridge sections, lock-gates, towers, lattice masts, roofs, roofing frameworks, door and window frames, shutters, balustrades, columns, pillars, and posts, and other structures and parts of structures, all the foregoing of base metal:
Of iron or steel:
Other.6.7% ad val.

Alternatives claimed by plaintiff:

A. Schedule 6, Part 5, item 685.70 provides in pertinent part:

Bells, sirens, indicator panels, burglar and fire alarms, and other sound or visual signalling apparatus, all the foregoing which are electrical, and parts thereof * * *
Other.3% ad val.

[909]*909B. Schedule 6, Part 5, item 683.32 provides in pertinent part:

Vacuum cleaners, floor polishers, food grinders, and mixers, juice extractors and other electro-mechanical appliances, all the foregoing with self-contained electric motors, of types used in the household, hotels, restaurants, offices, schools, or hospitals (but not including factory or other industrial appliances or electro-thermic appliances), and parts thereof:
*1* »Sa a, «7» -I* -J- *7»
Other.
4* ‡ ‡ ‡ $
Other electro-mechanical appliances.4.7% ad val.

C. Schedule 7, Part 4, item 727.70 provides in pertinent part:

Furniture, and parts thereof, not specifically provided for:
H* H* H« H* H« ❖ H«
Other.5.5% ad val.

Customs’ alternative classification:

Schedule 6, Part 3, Subpart G, item 657.25 provides in pertinent part:

Articles of iron or steel, not coated or plated with precious metal:
$ ‡ ‡ ‡ ‡ ^
Other articles:
H« ❖ H* * H* H« ❖
Other
H* H* ❖ H* H* *
Other.6.7 ad val.

Contentions of the Parties

Plaintiff contends that the Openmatic was improperly classified as "structures and parts of structures.” Plaintiff asserts the merchandise is not a structure because it will not sustain a heavy load, and it is not a part of a structure because each section is independent and free standing. Plaintiff contends that even if the Openmatic were a structure or part of a structure, other TSUS items more specifically describe it. Accordingly, plaintiff sets forth three classifications, any of which, plaintiff maintains, are more specific than TSUS item 653.00.

Plaintiff contends that the Openmatic should be classified as "other sound or visual signalling apparatus” under TSUS item 685.70 because its primary function is that of an alarm which deters unauthorized exits.

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Bluebook (online)
13 Ct. Int'l Trade 907, Counsel Stack Legal Research, https://law.counselstack.com/opinion/supermarket-systems-us-inc-v-united-states-cit-1989.