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Issues: Whether the impugned products were classifiable under Heading 84.19 as machinery, plant or laboratory equipment designed to treat materials by a process involving a change of temperature, or under Heading 90.18 as instruments and appliances used in medical science.
Analysis: The goods were admitted to be used for treating materials by a process involving change of temperature. The scope of Heading 84.19, read with the HSN explanatory notes, covered machinery and plant designed to subject materials to heating or cooling so as to cause a simple change of temperature or a transformation principally resulting from temperature change. The fact that the goods were used in medical or surgical sciences did not take them out of Heading 84.19, because the exclusion in Chapter 90 and the note to Section XVI did not justify reading into Heading 84.19 an exception for laboratory equipment used in medical sciences. On that reasoning, the specific medical-science description under Heading 90.18 could not prevail over the functional description of the goods under Heading 84.19.
Conclusion: The impugned products were correctly classifiable under Heading 84.19 and not under Heading 90.18.