Tariff classification of shower cabins turns on whether they are sanitary ware, not pre-fabricated buildings.

Imported shower cabins were held to be classifiable as sanitary ware under sub-heading 7615.20 because Note 4 to Chapter 94 limits pre-fabricated buildings to units finished in the factory or assembled on site as buildings, and the cabins were only bathroom fittings for showering. The goods were not buildings themselves, and the Explanatory Notes to Heading 76.15 supported treatment as articles of the same type as sanitary ware. Classification under Heading 94.06 was therefore rejected.

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Issues: Whether imported shower cabins are classifiable as pre-fabricated buildings under Heading 94.06 or as sanitary ware under Heading 7615.20 of the Customs Tariff.

Analysis: Note 4 to Chapter 94 confines pre-fabricated buildings to buildings finished in the factory or assembled on site as buildings. The goods in question were shower cabins meant to be fitted in a bathroom and used for showering, and there was nothing to show that they were buildings themselves. The Explanatory Notes to Heading 76.15 covered articles of the same type as sanitary ware, and the goods were found to fit within that tariff description.

Conclusion: The shower cabins are classifiable under sub-heading 7615.20 of the Customs Tariff and not under Heading 94.06.

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