Soda maker parts classification turns on dedicated use and essential character, not the gas content inside the cylinder.

A cylinder filled with carbon dioxide and specially designed for a home soda maker was treated as a part of that machine, because Section Note 2(b) and Section Note 4 of Section XVI require parts suitable solely or principally for use with a particular machine to be classified with the machine, and components contributing together to a defined function to fall under the relevant machine heading. Its dedicated design and integral role in the soda maker were decisive. The presence of CO2 and the lower value of the gas content did not alter the essential character of the article, so the refill cylinder was classifiable under Tariff Heading 8422.90 and not as carbon dioxide under Tariff Heading 2811.10.

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Issues: Whether a cylinder filled with carbon dioxide and specially made for use with a home soda maker is classifiable as a part of the soda maker under Tariff Heading 8422.90, or as carbon dioxide under Tariff Heading 2811.10.

Analysis: The classification had to be determined with reference to Section Note 2(b) and Section Note 4 of Section XVI of the Central Excise Tariff Act, 1985. Those notes require parts suitable solely or principally for use with a particular machine to be classified with that machine, and treat a machine made of components intended to contribute together to a defined function as falling under the heading appropriate to that function. The cylinder in question was specially designed for the home soda maker, was suitable only for that apparatus, and functioned as an integral component of it. The fact that it contained CO2 and that the gas content was cheaper than the cylinder itself did not change the essential character of the supply, since a purchaser of the refill cylinder was in substance obtaining a specially designed part for the soda maker, not generic CO2 for independent use.

Conclusion: The cylinder filled with CO2 was classifiable as a part of the home soda maker under Tariff Heading 8422.90 and not under Tariff Heading 2811.10.

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