Functional classification of office machinery: parts follow the machine's own heading where the main unit performs a specific non-data-processing function.

Imported refurbished stacker modules with accessories were examined for tariff classification as parts and accessories of machines under Heading 8472. The key issue was whether they could instead fall under sub-heading 8473.50 as goods equally suitable for use with machines of two or more Headings 84.69 to 84.72. The analysis treated the main machine as performing a specific function other than data processing, so Note 5(E) of Chapter 84 required classification by its own functional heading or, failing that, a residual heading. On that basis, the machine was classified as an other office machine under sub-heading 8472.90, and the parts were classified accordingly; the importer's claim under sub-heading 8473.50 was rejected.

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Issues: Whether the imported refurbished stacker modules with accessories were correctly classified as parts and accessories of machines falling under Heading 8472, and consequently under sub-heading 8473.40, rather than under sub-heading 8473.50 claimed by the importer.

Analysis: The item was found to be used for sorting cheques after reading the information contained in them, and the classification dispute turned on the true character of the main machine with which the parts were used. The claimed classification under sub-heading 8473.50 required the goods to be equally suitable for use with machines of two or more of Headings 84.69 to 84.72. The materials showed that the main machine performed a specific function other than data processing and, by virtue of Note 5(E) of Chapter 84, had to be classified according to its own function or, failing that, in a residual heading. The machine was treated as an other office machine under sub-heading 8472.90 and not as an input or output unit under Heading 8471.60. On that basis, the parts were correctly regarded as parts and accessories of Heading 8472.

Conclusion: The classification adopted by the department was upheld, and the importer's claim under sub-heading 8473.50 was rejected.

Ratio Decidendi: Where a machine performs a specific function other than data processing, its classification is governed by its own functional heading or the residual heading, and parts thereof are classifiable accordingly rather than as parts equally suitable for multiple headings absent the requisite common suitability.

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