Classification of tailor-made refrigeration parts turns on Section XVI notes and principal use, placing them under refrigerating machinery.

Tailor-made condensers, chillers, intercoolers, oil coolers and heat exchangers used in refrigeration plants are classified by reference to Section XVI notes and the HSN Explanatory Notes. Because the goods were not specifically named under Heading 8419 and were shown to be made for sole or principal use with refrigeration systems, Note 2(b) required classification with refrigerating machinery. End-use arguments did not displace the statutory notes, and the HSN material also supported treating condensers as parts of compression type refrigerators. The goods therefore fall under Heading 8418.90 as parts of refrigerating machinery, not under Heading 8419.90.

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Issues: Whether tailor-made condensers, chillers, intercoolers, oil coolers and heat exchangers supplied for use in refrigeration plants were classifiable as parts of refrigerating machinery under Heading 8418.90 or under Heading 8419.90 as parts of machinery for treatment of materials by change of temperature.

Analysis: Classification of parts of machines must be determined primarily by the section notes and chapter notes, with the HSN Explanatory Notes used as an aid. Note 2(a) of Section XVI did not apply because the goods were not specifically named under Heading 8419. Under Note 2(b), parts suitable for use solely or principally with a particular kind of machine are to be classified with that machine. The goods were admitted to be tailor-made and used as parts or accessories in refrigeration systems or plants of customers, and were not shown to have multipurpose use or to be equally suitable for machines under Heading 8419. The reliance on end-use and on the decisions cited by the appellant did not assist, because the classification turned on the statutory notes governing parts. The HSN material also supported treatment of condensers as parts of compression type refrigerators.

Conclusion: The goods were correctly classifiable under Heading 8418.90 as parts of refrigerating machinery, and not under Heading 8419.90.

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