Essential character test governs classification of imported bus air-conditioning components as a complete machine.

Imported components of a bus air-conditioning system were treated as a complete air-conditioner because the assembly, taken as a whole, had the essential character of the finished machine under the interpretative rules. The absence of ducting, wiring and certain connectors did not prevent classification on that basis, since the goods were intended only for use as a bus air-conditioner and could not reasonably serve another function. The claimed exemption for individual parts therefore did not alter the department's classification approach, and the essential-character test governed both classification and exemption treatment.

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Issues: Whether the imported goods were correctly classified as a complete air-conditioner for a bus on the basis that the constituent parts gave the assembly its essential character, and whether the claimed exemption notifications were available.

Analysis: The goods were found to consist of evaporator-condenser assembly, compressor, diesel engine and refrigeration unit, with additional undeclared items. The absence of ducting, electrical wiring and certain connectors did not prevent application of the interpretative rule relied upon by the Commissioner. On the facts, the assembly was intended for use only as a bus air-conditioner and could not reasonably be put to any other use, so it had the essential character of a complete air-conditioning system. The claimed exemption on the parts therefore did not displace the classification adopted by the department.

Conclusion: The classification adopted by the Commissioner was upheld and the appeal failed.

Final Conclusion: The import was treated as a complete air-conditioning unit for classification and exemption purposes, with the departmental view sustained.

Ratio Decidendi: Where imported components together give an assembly the essential character of a complete machine, classification follows that essential character under the interpretative rules.

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