Functional tariff classification for satellite receiver equipment depends on combined reception and transmission use, not nomenclature or assumed predominance.

Imported satellite receiver equipment designed to both receive satellite signals and transmit them through a cable network was analysed by its combined functional character for tariff classification. The classification could not depend on the manufacturer's description or on an assumed predominance of reception over transmission. Because reception was necessary for transmission and transmission was the equipment's operative purpose in the cable network, the interpretative material did not support treating it as television reception apparatus under Heading 85.28. The equipment was therefore classifiable under Heading 8525.20 as transmission apparatus incorporating reception apparatus.

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Issues: Whether the imported satellite receiver equipment was correctly classifiable under Heading 8525.20 as transmission apparatus incorporating reception apparatus, or under Heading 85.28 as reception apparatus for television.

Analysis: The goods were designed to perform two functions, namely reception of satellite signals and transmission of those signals through the cable network to subscribers. Classification could not rest merely on the manufacturer's description or on the supposed predominance of one function over the other. The functional design of the equipment showed that reception was necessary for transmission and transmission was the very purpose of the equipment in the cable network. The reliance placed on the goods being received through line transmission in support of Heading 85.28 was found to be misplaced, and the interpretative guidance did not justify treating the goods as television reception apparatus.

Conclusion: The goods were held classifiable under Heading 8525.20 and not under Heading 85.28, in favour of the assessee.

Ratio Decidendi: Where imported equipment is designed to both receive and transmit signals as part of a cable network, tariff classification must be determined by its combined functional character and not by nomenclature or an assumed primary function.

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