&&The products are aluminum die cast parts specifically manufactured to be used to build solar cover reel system for swimming pools. The parts form the base, frame, legs, hubs and handles with knobs of the reel systems for swimming pool covers. The reel system serves to furl and unfurl swimming pool covers by manually rotating the handle attached to the rolled up pool covers.

&&In your request for an Advance Ruling you proposed tariff classification under 8479.90.90.90.&&This tariff classification number is incorrect.&&&&Legal Note 1(p) to Section XVI excludes goods of Chapter 95. Chapter 95 legal Note 3 states that parts and accessories which are suitable for use solely or principally with articles of this chapter are to be classified with those articles. Swimming Pools are specifically named in heading 95.06.&&&&In accordance with Memorandum D10-0-1, Classification of Parts and Accessories in the Customs Tariff, for the purpose of tariff classification the Canada Border Services Agency (CBSA) defines “accessory” as “an article which performs a secondary or subordinate role, not essential to the function, which could improve the effectiveness of the host machine, equipment, apparatus or appliance”. The CBSA defines a “part” as “an identifiable component of an article, machine, apparatus, equipment, appliance or specific good which is integral to the design and essential to the function of the product in which it is used”.&&&&Exclusionary Note 1(p) to Section XVI requires that the starting point of classification be Chapter 95. There is no competing exclusionary note directing that articles of Chapter 84 are excluded from Chapter 95.&&&&As they improve the effectiveness of swimming pools, swimming pool covers are classified in heading 95.06; they are accessories for use solely or principally swimming pools, and as such are articles of Chapter 95 in accordance with Chapter 95 legal Note 3. As they improve the effectiveness of swimming pool covers, reel systems are classified in heading 95.06; they are accessories for use solely or principally with swimming pool covers classified in heading 95.06, and as such are also articles of Chapter 95 in accordance with Chapter 95 legal Note 3. The products are “parts” of the reel systems because they are integral to the design and required for the reels to function. They are also suitable for use solely or principally with the reel systems. As the products consist of the parts that form the base, frame, legs, hubs and handles with knobs of the reel systems, and they are suitable for use solely or principally with articles of Chapter 95, they are classified in heading 95.06 in accordance with Chapter 95 legal Note 3.