Customs classification of programmable inverters: automatic control functions supported Heading 90.32, not mere inverter classification.

Imported general purpose inverters were examined for tariff classification by reference to their configuration, function and technical characteristics. Technical literature and expert opinion showed that the goods were programmable, could convert AC to DC and DC to AC, and could automatically control electrical quantities, including stall prevention. On that basis, they were treated as more than mere inverters under Heading 85.04 and were held to fall within Heading 90.32 as automatic regulators of electrical quantities. The Department produced no rebuttal evidence to displace the technical finding, so the Revenue's challenge failed.

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Issues: Whether the imported general purpose inverters were classifiable under Heading 90.32 of the Customs Tariff Act, 1975 as automatic regulators of electrical quantities, or under Heading 85.04 as inverters.

Analysis: The classification depended on the goods' configuration, function, and technical characteristics. The lower appellate authority relied on detailed technical literature and expert opinions from professors of electrical engineering, and found that the goods were programmable, capable of converting AC to DC and DC to AC, and able to automatically control electrical quantities such as stall prevention. The Department did not produce rebuttal evidence to dislodge that technical finding. The distinction drawn was that a mere inverter would fall under Heading 85.04, but the imported equipment had additional control functions bringing it within Heading 90.32.

Conclusion: The goods were correctly classifiable under Heading 90.32 and not Heading 85.04; the Revenue's challenge failed.

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