Tariff classification depends on product function: programmable data-processing features supported Heading 8471.00 over Chapter 90 parts.

Tariff classification turned on the essential functional characteristics of the goods shown in the product literature. The goods had time-programmed functions, a high degree of flexibility, wide operating parameters, and pre-programmed post-run data reduction calculations with automatic calibration and recalibration, indicating that they were programmable and capable of arithmetical computation. On that basis, they satisfied the attributes of an automatic data processing machine under Heading 8471.00. Classification under Heading 9033.00 was rejected because the goods were not established to be mere parts or accessories of Chapter 90 measuring instruments. The Revenue's challenge succeeded and the classification in favour of the Revenue was restored.

---

---

Issues: Whether the goods manufactured by the respondent were classifiable under Heading 8471.00 as automatic data processing machines or under Heading 9033.00 as parts and accessories of Chapter 90.

Analysis: Heading 8471.00 covers automatic data processing machines, and Chapter Note 5(a) to Chapter 84 requires, inter alia, that such machines store the processing program or programs and necessary data, be freely programmed according to user requirements, perform arithmetical computations specified by the user, and execute a processing program without human intervention with logical decision-making during processing. On the product literature, the goods were capable of time-programmed functions, offered a high degree of flexibility, permitted a wide range of operating parameters, and were pre-programmed to perform post-run data reduction calculations, including area percentage, normalisation, and internal and external standard calculations with automatic calibration and recalibration. These features showed that the goods were programmable and capable of arithmetical computations. The classification under Heading 9033.00 was rejected because the goods were not shown to be mere parts or accessories of measuring instruments of Chapter 90.

Conclusion: The goods were correctly classifiable under Heading 8471.00 and not under Heading 9033.00.

Final Conclusion: The Revenue's challenge succeeded, the order of the Commissioner (Appeals) was set aside, and the classification in favour of the Revenue was restored.

Ratio Decidendi: For tariff classification, the essential functional characteristics of the goods, as demonstrated by their product literature, determine whether they satisfy the statutory attributes of an automatic data processing machine under Chapter 84.

---