Built around Johnson Lifts Pvt. Ltd. v. Commissioner of Customs, Chennai-II (CESTAT Chennai, Final Order No. 40054/2026, 9 January 2026)
Why this concept deserves a dedicated study
Few expressions in the Harmonized System cause as much repeat litigation as “parts of general use.” It sits at the exact fault line where two intuitions collide:
- “This bolt was made specifically for a lift, so it must be a lift part.” (the importer’s instinct)
- “A bolt is a bolt, classified as a bolt wherever it goes.” (the Nomenclature’s design)
The Harmonized System resolves this collision deliberately and against the first instinct. A defined class of humble fasteners, springs, chains, and fittings is pulled out of the “parts” logic entirely and pinned to its own base-metal heading regardless of what machine it is destined for. The Johnson Lifts judgment is a clean teaching vehicle because the Department tried to invoke this rule across ten different items – and lost on every one, not because the rule is weak, but because the rule has conditions that must be proved. The case teaches the concept from both sides: what the rule is, and what it takes to actually trigger it.
What “parts of general use” actually means
The governing definition: Note 2 to Section XV
The expression is not a loose description. It is a closed, exhaustively defined term fixed by Note 2 to Section XV, and it carries the same meaning everywhere in the Nomenclature. The Note defines “parts of general use” as:
(a) Articles of heading 73.07 (tube or pipe fittings), 73.12 (stranded wire, ropes, cables), 73.15 (chain), 73.17 (nails, tacks, etc.), or 73.18 (screws, bolts, nuts, washers, etc.), and similar articles of other base metal, other than articles specially designed for use exclusively in medical/surgical/dental/veterinary implants (heading 90.21);
(b) Springs and leaves for springs, of base metal, other than clock or watch springs (heading 91.14); and
(c) Articles of headings 83.01 (locks), 83.02 (mountings, fittings, hinges, castors), 83.08 (clasps, buckles, eyelets), 83.10 (sign-plates, name-plates), and frames and mirrors of base metal of heading 83.06.
Two structural features make this Note powerful:
- It is a definition, not a heading. It does not classify anything by itself; it labels a class of goods so that other Notes throughout the Nomenclature can refer to that class with a single phrase.
- It reaches across the whole Nomenclature. The opening words “Throughout the Nomenclature” mean the same list applies in Section XVI (machinery), Section XVII (vehicles), Chapter 90 (instruments), and everywhere else.
The operative consequence: the part loses its “destination”
The decisive sentence sits in the General Explanatory Note to Section XV, under “Parts of Articles”:
“… parts of general use (as defined in Note 2 to this Section) presented separately are not considered as parts of articles, but are classified in the headings of this Section appropriate to them. This would apply, for example, in the case of bolts specialised for central heating radiators or springs specialised for motor cars. The bolts would be classified in heading 73.18 (as bolts) and not in heading 73.22 (as parts of central heating radiators). The springs would be classified in heading 73.20 (as springs) and not in heading 87.08 (as parts of motor vehicles).”
This is the heart of the concept. Specialisation does not rescue the item. A bolt machined to the exact tolerance of one radiator model is still a bolt of 73.18. A leaf spring built for one car is still a spring of 73.20. The destination – the radiator, the car, the lift – is legally irrelevant for these defined goods. The HS deliberately strips the “for use with X” reasoning away from this narrow class to keep classification of common hardware uniform and predictable worldwide.
How the exclusion is wired into each Section
The definition would be inert without exclusionary Notes that use it. They appear in every Section that deals with parts:
| Where | Exclusion mechanism |
| Section XVI (machinery) | Note 1(g): the Section “does not cover … parts of general use, as defined in Note 2 to Section XV, of base metal (Section XV), or similar goods of plastics (Chapter 39).” |
| Section XVII (vehicles, aircraft, vessels) | Note 2(b): parts and accessories that are “parts of general use” are excluded from the parts headings – the EN even lists cable, chain, nails, bolts, nuts, washers, cotters, springs, and coachwork locks/hinges by name. |
| Chapters 73–76, 78–81 | Note 2 to Section XV itself: “In Chapters 73 to 76 and 78 to 81 (but not in heading 73.15) references to parts of goods do not include references to parts of general use.” |
| Chapter 82 (tools) | Chapter Note 2: “parts of general use as defined in Note 2 to Section XV are in all cases excluded from this Chapter.” |
| Chapter 83 (misc. base metal) | Chapter Note 1: articles of 73.12, 73.15, 73.17, 73.18 or 73.20 “are not to be taken as parts of articles of this Chapter.” |
The pattern is consistent: wherever a “parts” basket exists, parts of general use are carved out of it and sent home to their own base-metal heading.
The deliberate exceptions – proof the rule is intentional
The HS even builds in two narrow escape hatches, which confirm the rule is a conscious design choice rather than an accident:
- Medical/surgical implants. Articles otherwise within 73.18 etc. that are specially designed for use exclusively in medical, surgical, dental, or veterinary implants escape the definition and go to heading 90.21. The Nomenclature only grants this for a context where it explicitly chose to.
- Heading 73.15 carve-out for Chapter parts references. The parenthetical “(but not in heading 73.15)” preserves chain’s own “parts” logic in one place, showing the drafters tuned the rule heading by heading.
The takeaway: when the HS wants a specialised part to follow its machine, it says so. Silence means the general rule governs – the part stays with its own heading.
The case: facts and the classification battlefield
The importer and the goods
Johnson Lifts Pvt. Ltd. runs turnkey lift and escalator installation projects. It imported seventeen categories of components, every one declared under CTH 8431 – specifically tariff item 8431 31 00, the WCO subheading 8431.31, “Of lifts, skip hoists or escalators,” which sits under heading 84.31, “Parts suitable for use solely or principally with the machinery of headings 84.25 to 84.30.”
The Department’s reclassification
After an audit, the Department issued a show cause notice reclassifying each item into its own heading and demanding ≈ Rs. 1.23 crore in differential duty, plus a Rs. 3 crore redemption fine and ≈ Rs. 1.35 crore in penalties, invoking the extended period of limitation.
The items and the “parts of general use” logic that should, in principle, govern several of them:
| Item | Dept’s heading | WCO 6-digit | Falls within PGU definition? |
| Angle Steel | 7308 90 90 | 7308.90 | No – 73.08 is not in the Note 2 list |
| Belt | 4010 39 99 | 4010.39 | No – rubber belt; excluded by Note 1(a), not 1(g) |
| Bolt & Nut | 7318 15 / 7318 16 | 7318.15 / 7318.16 | Yes – 73.18 is squarely listed |
| Brush | 9603 50 00 | 9603.50 | No – excluded by Note 1(o), not PGU |
| Chain | 7315 12 90 | 7315.12 | Yes – 73.15 is listed |
| Clamp | 8205 70 00 | 8205.70 | No – Chapter 82 article (Note 1(k)) |
| Clip | 7326 90 99 | 7326.90 | Arguable – 73.26 is not in the list |
| Door Lock | 8301 40 90 | 8301.40 | Yes – 83.01 is listed (and see Part 4) |
| Fish Plate | 7326 90 99 | 7326.90 | Arguable – 73.26 not listed |
| Hinge | 8302 10 90 | 8302.10 | Yes – 83.02 is listed |
| Push Button | 8536 50 90 | 8536.50 | No – electrical apparatus |
| Rope | 7312 10 90 | 7312.10 | Yes – 73.12 is listed |
| Springs | 7320 20 00 | 7320.20 | Yes – springs are listed (limb (b)) |
| Springs Pin | 7320 90 20 | 7320.90 | Yes – springs (limb (b)) |
| Switch | 8536 50 90 | 8536.50 | No – electrical apparatus |
| Washer | 7318 22 00 | 7318.22 | Yes – 73.18 is listed |
| Buzzer | 8531 10 90 | 8531.10 | No – electrical apparatus |
This table itself is an instructive exercise: notice that the Department’s “parts of general use” theory was textually correct in form for the genuine 73.12 / 73.15 / 73.18 / 73.20 / 83.01 / 83.02 items, but over-reached for angle steel (7308), clip and fish plate (7326), which are not in the Note 2 list at all. The label “parts of general use” was being used loosely to mean “ordinary hardware,” when it is in fact a closed list.
Why the Department lost despite a textually plausible rule
Here is the lesson that surprises newcomers: the “parts of general use” exclusion is mandatory and cannot be defeated by end-use – yet the importer still won. The reconciliation is entirely about proof and procedure, not about the strength of the rule.
1. The exclusion is real, but it is a finding of fact that must be evidenced
Note 1(g) only bites if the goods are in fact parts of general use within Note 2 to Section XV. That is a factual characterisation the Department must establish. To put a bolt in 73.18 as a “part of general use,” Revenue must show the article genuinely answers the description of a bolt of 73.18 – not merely that it is called a bolt on an invoice.
The Tribunal found the record empty. There was no product literature, no expert opinion, no test report establishing that the angle steel, bolts, nuts, chain, clip, fish plate, rope, springs, springs pin, and washer were ordinary general-use hardware rather than purpose-built lift components. The importer, by contrast, put on record uncontroverted evidence that the angle steels were uniquely numbered and pre-drilled and the bolts/nuts were special types unusable elsewhere. Burden of proof rests on Revenue when it disturbs a declared classification, and that burden was not discharged.
Teaching point. The PGU rule is unbeatable once the goods are shown to be PGU – but showing it is the Department’s job. An importer cannot use “it’s specialised” to escape a proven bolt-of-73.18; but the Department cannot win merely by asserting the item is a bolt of 73.18. Both sides are disciplined by the same definition.
2. The grounds were raised outside the show cause notice
The SCN’s only stated basis was GRI 1 plus the EN to 84.31 (the caution that “many parts do not fall in this heading … e.g. suspension springs (heading 73.20)”). The specific Section XVI Note 1 exclusions – 1(g), 1(a), 1(o), 1(k) – and Note 2(a) were not invoked in the SCN. They first appeared in the adjudication order. Supplying fresh legal grounds in the final order, behind the noticee’s back, violates natural justice; the SCN is the foundation of the case and the adjudicating authority cannot travel beyond it.
3. Residuary headings were preferred over specific entries
The Department consigned most items to “others” residuary sub-headings. This offends the settled rule that a specific entry is preferred to a residuary one – a specific entry is not to be denied to an article that has a reasonable claim to it.
4. The heading the importer chose does permit use as a criterion
Heading 84.31 reads “Parts suitable for use solely or principally with the machinery of headings 84.25 to 84.30.” That wording inherently incorporates use as a classification test. Relying on the Supreme Court’s January 2026 decision in Welkin Foods (2026 INSC 19), the Tribunal held that “use” is a legitimate criterion because the heading text invites it. So for any item not caught by a Note 1 exclusion, the importer’s exclusive lift/escalator business plus the tailor-made nature of the goods satisfied the “solely or principally” standard at GRI 1.
This is the crucial interaction: the PGU exclusion (Note 1(g)) and the use-based heading (84.31) are in tension, and the exclusion wins where it applies. A proven part of general use goes to its own heading even though 84.31 would otherwise have taken it on use grounds. The importer prevailed only because the exclusion was never proven to apply.
The door-lock counter-example: the rule biting in the open
Door locks are the most valuable teaching item in the whole case, because here the importer lost – and lost cleanly. The contrast isolates exactly how the exclusion machinery works when it is properly engaged.
Two independent routes pointed the door locks to heading 83.01 (subheading 8301.40, “Other locks”):
- Parts of general use. Locks of 83.01 are expressly listed in Note 2(c) to Section XV. A lock is therefore a part of general use, excluded from Section XVI by Note 1(g) even if used solely in lifts – precisely the radiator-bolt / car-spring logic from the General EN.
- A specific EN exclusion. The Explanatory Note to heading 84.31 expressly excludes “locks for passenger and goods lifts, etc. (heading 8301),” and the EN to 83.01 expressly covers locks “for lifts.” This exclusion was flagged in the SCN.
The Tribunal upheld the reclassification of door locks to 83.01 because the importer offered no reason why the specific exclusion should not apply. Note the elegance: the same “used solely in lifts” argument that saved the unproven items could not save the door locks, because for locks the exclusion was both squarely within the PGU definition and specifically pleaded. Correct application of the rule is not a one-way ratchet for the importer – it follows the text wherever it leads.
Teaching point. Door locks show the PGU rule operating as designed: an article on the Note 2 list goes to its own heading irrespective of its lift-only destiny. The other items escaped not because the rule is different for them, but because the Department never did the work to place them on the list with evidence.
A clean decision procedure for “parts of general use”
Use this sequence whenever a base-metal or plastic part is presented “for a machine, vehicle, or instrument”:
Step 1 – Identify the candidate heading of the part itself. Is the article, on its own terms, a tube/pipe fitting (73.07), stranded wire/rope/cable (73.12), chain (73.15), nail/tack (73.17), screw/bolt/nut/washer (73.18), a spring (73.20), a lock (83.01), a mounting/fitting/hinge/castor (83.02), a clasp/buckle (83.08), a sign-plate (83.10), or a frame/mirror of 83.06 – or a similar article of another base metal?
- Yes → go to Step 2.
- No → it is not a part of general use; classify it as a part of its machine/vehicle/instrument under the normal parts rules (e.g. Section XVI Note 2, Section XVII Note 3). This is where angle steel (7308), clip and fish plate (7326) sat – outside the PGU list, so the exclusion never applied to them in form.
Step 2 – Apply the definition (Note 2 to Section XV) literally. The list is closed and exhaustive. Confirm the item genuinely answers the heading description as a matter of fact, supported by evidence (literature, samples, test report). Mere nomenclature on an invoice is not enough.
Step 3 – Check the two carve-outs. Is it specially designed for exclusive use in a medical/surgical/dental/veterinary implant (→ 90.21)? Is it a clock/watch spring (→ 91.14)? If so, it leaves the PGU definition.
Step 4 – Apply the exclusion, ignoring destination. If it is a part of general use, classify it in its own base-metal heading. Specialisation for one machine is legally irrelevant (radiator bolt → 73.18; car spring → 73.20; lift lock → 83.01). The “for use with X” reasoning is switched off for these goods.
Step 5 – Who must prove what. If the Department is displacing a declared classification, it must evidence that the goods are PGU. If the importer claims a use-based heading (like 84.31) for an item that is not PGU, the importer must show the goods meet the “solely or principally” standard from their objective characteristics.
Five misconceptions this case corrects
- “My part was custom-made for one machine, so it follows that machine.” False for the defined class. A bolt built to one radiator’s spec is still a bolt of 73.18. Custom design does not lift an article out of the PGU list.
- “‘Parts of general use’ just means ordinary or generic hardware.” False. It is a closed list of specific headings (73.07/12/15/17/18, springs, 83.01/02/06/08/10), not a vibe. Angle steel of 73.08 and clips of 73.26 are not on the list – calling them “general use” is an error of law.
- “The exclusion is weak – Johnson Lifts beat it ten times.” False. The exclusion is mandatory and unbeatable when proven. The Department lost on evidence and procedure, not on the strength of the rule. The door locks show the rule winning the moment it is properly engaged.
- “End-use is never relevant in classification.” Too absolute. Use is relevant where the heading text invites it (84.31’s “solely or principally”). But a Section/Chapter Note exclusion – like the PGU exclusion – overrides a use-based heading. Notes outrank the use argument.
- “A specialised lift lock used only in lifts must be a lift part.” False. Locks are PGU (Note 2(c)) and 84.31’s own EN sends lift locks to 83.01. Destination loses to the defined exclusion.
Authorities relied on
| Source | Point it establishes |
| Note 2 to Section XV | The closed definition of “parts of general use.” |
| General EN to Section XV, “Parts of Articles” | Specialised bolts/springs stay in 73.18 / 73.20, not the machine’s parts heading. |
| Section XVI, Note 1(g) | Machinery Section does not cover PGU of base metal. |
| Section XVI, General EN (exclusions) | Lists wire, chains, bolts, screws, springs (73.12/15/18/20), locks (83.01), fittings (83.02) as excluded PGU. |
| Section XVII, Note 2 + EN | Mirror exclusion for vehicles, naming bolts, nuts, washers, springs, coachwork hinges/locks. |
| Chapter 82, Note 2 / Chapter 83, Note 1 | PGU excluded from the tools and misc-base-metal “parts” baskets. |
| EN to heading 84.31 | “Many parts do not fall here … e.g. suspension springs (73.20)”; and excludes “locks for passenger and goods lifts (83.01).” |
| EN to heading 83.01 | Expressly covers locks for lift doors, including electrically operated lift-door locks. |
| EN to heading 73.20 | Springs of all types, irrespective of use, fall here (other than clock/watch springs of 91.14). |
| GRI 1 | Headings and relative Section/Chapter Notes are paramount; Notes govern. |
| GRI 6 | Subheading comparison at the same level (e.g. resolving 8301.40). |
Closing synthesis
The “parts of general use” concept exists to keep the world’s commonest hardware – bolts, nuts, washers, springs, chains, ropes, locks, hinges – classified uniformly, free from the gravitational pull of whatever machine they happen to serve. The rule is mandatory, defined by a closed list, and immune to end-use arguments: a part of general use goes to its own base-metal heading even when it is purpose-built for a single application, as the radiator-bolt and car-spring illustrations in the Explanatory Notes make explicit.
Johnson Lifts teaches the concept in stereo. On one channel, the Department failed to exclude ten items – not because the rule is soft, but because it never proved, on evidence and within the four corners of its notice, that the goods were genuinely parts of general use, and because the heading the importer chose (84.31) lawfully admits a use-based test. On the other channel, the door locks were correctly excluded to 83.01, showing the rule operating exactly as designed the instant it was properly invoked. The enduring lesson for the classifier is therefore twofold: know the closed list cold, and remember that invoking the exclusion is a matter of proof, not assertion.
Prepared as an educational reference. Classification advice is grounded in the WCO Harmonized System, Seventh Edition (2022), and its Explanatory Notes. National tariff items shown (8-digit) are illustrative breakdowns to be confirmed against the applicable national schedule; the HS is harmonized only to the 6-digit subheading level. This study is not a binding ruling.