Classification of ODU Controller PCB as air-conditioner part upheld over stand-alone electric control heading.

Imported ODU Controller PCB assemblies used solely in the outdoor unit of an air conditioner were held to be classifiable as parts of air-conditioning machines rather than as stand-alone control apparatus. Applying Section Note 2(b) of Section XVI, the Authority found that goods suitable solely or principally for use with a particular machine must be classified with that machine. Because the PCB had no independent function or operability apart from the air-conditioning system, it did not meet the description of an apparatus under Heading 8537 and was classified under sub-heading 84159000.

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Issues: Whether the imported ODU Controller PCB is classifiable under Heading 8537 as a board or panel equipped with apparatus for electric control or distribution, or under Heading 84159000 as a part of an air conditioner.

Analysis: The goods were found to be populated PCB assemblies meant for use only as components of the outdoor unit of an air conditioner and not as stand-alone apparatus. The classification exercise was therefore governed by Section Note 2(b) of Section XVI of the Customs Tariff Act, 1975, under which parts suitable solely or principally for use with a particular machine are to be classified with that machine. The Authority held that the reliance placed on stand-alone products classified under Heading 8537 was not apt because the imported goods did not possess an independent function or independent operability. Applying the test whether the item has a separate identifiable function and whether it can operate independently, the Authority concluded that the ODU Controller PCB depends on the air-conditioning system and does not answer the description of an apparatus under Heading 8537.

Conclusion: The ODU Controller PCB is classifiable under Sub-heading 84159000 of the First Schedule to the Customs Tariff Act, 1975 and not under Heading 8537.

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