Airflow Technology, Inc. v. United States

Airflow Technologies, Inc. (Airflow) (plaintiff) imported Sperifilt, a filter media made up of layers of bonded polyester fibers commonly used in industrial paint-spray booths. The United States Customs Service (customs) (defendant) classified Sperifilt under Harmonized Tariff Schedule of the United States (HTSUS) subheading 5911.40.00, which applied to “staining cloth of a kind used in oil presses or the like.” Customs selected this classification in part because an explanatory note to heading 5911 stated that straining cloths for industrial dust-collecting systems were included under that subheading. Airflow challenged the classification, stating that subheading 5911.40.00 applied only to products used to separate solids from liquids using a pressure differential, as that was the essential characteristic of an oil press. Sperifilt, on the other hand, could be used only for air filtration. Instead, Airflow argued that Sperifilt should have been classified under heading 5603, which its explanatory note explained applied to sheets for filtering liquids or air. In response, customs argued that while Sperifilt was prima facie classifiable under both subheadings, subheading 5911.40.00 was the more specific one. The United States Court of International Trade agreed with customs, holding that “straining cloth,” which was not defined by the HTSUS, was synonymous with “filter cloth,” which applied to Sperifilt. Airflow appealed.