Tariff classification turns on nature and function: imported machinery fell outside the office machine heading.

Imported machinery was held not to be classifiable as an office machine under Tariff Heading 84.51/55 because classification depends on the machine's nature and function. On that basis, the machine fell outside the office machine heading and was instead to be classified under either Tariff Heading 84.32 or 84.66. The Court did not choose between those two headings because the rate of duty was the same under both, and it did not examine the countervailing duty issue since no argument was addressed on that point.

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Issues: Whether the imported machine was correctly classified as an office machine under Tariff Heading 84.51/55, or whether it fell under Tariff Heading 84.32 or 84.66.

Analysis: The machine had to be classified having regard to its nature and function. On that basis, it could not be treated as an office machine within Tariff Heading 84.51/55. The Court declined to decide between Tariff Headings 84.32 and 84.66 because the rate of duty under both headings was the same, and it also did not examine the countervailing duty issue since no argument was addressed on that aspect.

Conclusion: The machine was not classifiable under Tariff Heading 84.51/55 and was to be classified either under Tariff Heading 84.32 or Tariff Heading 84.66.

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