&&Chaoyang model CR960A (vulcanized) rubber tire mounted on a Jingu model JG28SW61X steel wheel.

&&The tire mounted on a wheel is identified as being for use with both trucks and trailers. It is marketed as a regional steer/trailer tire. Regional steer tires are used on trucks, buses, etc.&&Section XVII, Note 3 states:&&&&3. References in Chapters 86 to 88 to "parts" or "accessories" do not apply to parts or accessories which are not suitable for use solely or principally with the articles of those Chapters. A part or accessory which answers to a description in two or more of the headings of those Chapters is to be classified under that heading which corresponds to the principal use of that part or accessory.&&&&In this instance, the above Note applies equally to both headings 87.08 and 87.16 (parts of trucks and parts of trailers). The tire mounted on the wheel is suitably and principally for use with either vehicle. The Explanatory Notes to headings 87.08 and 87.16 read as follows:&&&&87.08 Parts of vehicles of headings 87.01 to 87.05.&&&&(i) They must be identifiable as being suitable for use solely or principally with the above-mentioned vehicles;&&87.16 "PARTS" of trailers, semi-trailers, etc.&&&&(i) They must be identifiable as being suitable for use solely or principally with such vehicles;&&&&Item (K) to the Explanatory Note to heading 87.08 includes "… wheels (pressed steel, wire-spoked, etc.), whether or not fitted with tyres (in Canada, spelled "tires"); …".&&&&Item (4) to the Explanatory Note to heading 87.16, under "PARTS" provides for the inclusion of steel wheels and parts thereof, including wheels fitted with their tires (for trailers and semi-trailers in the same heading).&&&&As the good in question is suitable for use with both trucks and trailers, it is not possible to determine the principal use of the tire mounted on the wheel, we must make reference to General Interpretative Rule (GIR) 3(c), which reads:&&&&When goods cannot be classified by reference to 3(a) or 3(b), they shall be classified under the heading which occurs last in numerical order among those which equally merit consideration.&&In the current case, the headings under consideration are headings 87.08 and 87.16. In applying GIR 3(c), the mounted tire on the wheel for use with trucks and trailers is classified in heading 87.16.&&