Tariff classification of compressor sub-assembly turns on essential character and incomplete article test

Imported Short Block Sub-Assembly was classified as parts of gas compressors for refrigerating and air conditioning machinery under Tariff Item 84149011 because it comprised the principal housing and mechanical components of a scroll compressor, but excluded the scroll set that performs the compression function and gives the finished compressor its essential character. Applying Rule 1 and Rule 2(a) of the General Rules for the Interpretation of the Import Tariff, read with Section Note 2 to Section XVI, the Authority found that the goods were neither an incomplete compressor with the essential character of the complete article nor a compressor in unassembled or disassembled form. Additional components and post-import operations in India were material to completion of the final compressor.

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Issues: Whether the imported Short Block Sub-Assembly was classifiable as parts of gas compressors of a kind used in refrigerating and air conditioning appliances and machinery under Tariff Item 84149011, or as a compressor in incomplete or unassembled form under Tariff Item 84143000.

Analysis: The classification was tested under Rule 1 and Rule 2(a) of the General Rules for the Interpretation of the Import Tariff, read with Section Note 2 to Section XVI. The imported goods were found to comprise the principal housing and mechanical components of a scroll compressor, but they did not include the scroll set, which is the component that performs the compression function and imparts the essential character of the finished compressor. The imported goods therefore did not answer the description of an incomplete compressor having the essential character of the complete article. The Authority also found that the goods were not presented as a compressor in unassembled or disassembled form, and that the post-import operations and additional components required in India were material to completion of the final compressor.

Conclusion: The Short Block Sub-Assembly is classifiable under Tariff Item 84149011 and not under Tariff Item 84143000.

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