HSN Explanatory Notes guided classification of a built-in snow-blower vehicle as a special purpose motor vehicle.

Tariff classification of a snow-blower turned on the Harmonised System of Nomenclature, because the Customs Tariff headings aligned with the HSN and no contrary intent appeared. The Explanatory Notes to Heading 84.30 exclude snow-blower vehicles of Section XVII with built-in equipment, while Heading 87.05 covers motor vehicles specially constructed for non-transport functions, including snow-ploughs and snow-blowers with built-in equipment. On the material and brochure, the goods were a vehicle with common engine, common drive, common control and built-in snow-clearance attachments, not a detachable snow-blower unit. The goods were therefore classifiable under Heading 87.05 and not under Heading 8430.20.

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Issues: Whether the imported snow-blower was classifiable under Heading 8430.20 as snow-ploughs and snow-blowers, or under Heading 87.05 as a special purpose motor vehicle.

Analysis: The classification dispute was resolved by reference to the Harmonised System of Nomenclature, since the corresponding tariff headings were identical and there was no indication of a contrary intention in the Customs Tariff. The Explanatory Notes to Heading 84.30 exclude snow-blower vehicles of Section XVII with built-in equipment, while Heading 87.05 includes motor vehicles specially constructed for non-transport functions, including snow-ploughs and snow-blowers with built-in equipment. The imported product was found, on the material and brochure, to be a snow-blower vehicle with common engine, common drive, common control and built-in snow clearance attachments, and not a detachable snow-blower unit alone.

Conclusion: The goods were correctly classifiable under Heading 87.05 and not under Heading 8430.20.

Ratio Decidendi: Where tariff headings are identical to the HSN, the HSN Explanatory Notes may be used to determine classification, and a vehicle with built-in snow-clearing equipment falls under the special purpose motor vehicle heading rather than the snow-blower heading.

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