## Facts

- Willoughby Camera Stores, Inc. imported wooden tripods designed for use with cameras.
- Customs classified the tripods as “parts of cameras” under paragraph 1551 of the Tariff Act of 1930, resulting in a higher duty.
- Willoughby protested, claiming the tripods were “manufactures of wood not specially provided for” under paragraph 412.
- The Customs Court sustained Customs’ classification.
- Evidence showed the tripods were used in connection with cameras, were suitable for that use, and other uses were limited and did not outweigh camera use.
- Testimony indicated that for larger/professional cameras, stable support was practically necessary to use the camera for its ordinary purpose, even though tripods were commonly sold separately.

## Issues

1. Whether the imported wooden tripods were properly classifiable as “parts of cameras” under paragraph 1551 of the Tariff Act of 1930 rather than as “manufactures of wood not specially provided for” under paragraph 412.
2. What standard determines when an item is a “part” of an article for tariff-classification purposes.

## Decision

- The Court of Customs and Patent Appeals affirmed the Customs Court.
- The tripods were properly classified as “parts of cameras” under paragraph 1551.
- The court treated the tripods’ principal and functionally necessary role in camera operation (for the cameras at issue) as controlling over the more general wood-manufactures provision.

## Legal Principles

- For tariff purposes, a “part” of an article is something necessary to the completion of that article, without which the article could not function as such.
- Predominant, dedicated use with the named article, combined with limited alternative uses, supports classification as a “part” rather than as a general article or accessory.
- When competing provisions could apply, a specific eo nomine provision for parts of an article prevails over a general residual provision describing the item by material (e.g., “manufactures of wood”).

## Conclusion

The court upheld classification of the imported wooden camera tripods as “parts of cameras” because the record showed they were chiefly used with cameras and were functionally necessary for the relevant cameras to operate as cameras, making the specific camera-parts provision govern over the general wood-manufactures provision.


United States v. Willoughby Camera Stores, Inc., 21 C.C.P.A. 322 (C.C.P.A. 1933)