Irrigation system components classify with the system itself when supplied as intended parts, securing the related exemption.

Pipes and fittings supplied as intended component parts of sprinkler and irrigation systems are classifiable with the system under Heading 84.24, not as separate pipes, tubes or hoses under Heading 39.17. Classification turned on their manufacture and supply as a package for specific irrigation systems, cut to size and assembled on site, and on their actual use solely as parts of those systems. Applying Section XVI Notes 4 and 5, the components contributed directly to the irrigation system's transportation and dispersal function. The exemption attached to Heading 84.24 was therefore available, and the duty demand could not be sustained.

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Issues: Whether pipes and fittings supplied for sprinkler and irrigation systems were classifiable as parts of irrigation systems under Heading 84.24 or as pipes, tubes or hoses and their fittings under Heading 39.17, and whether the exemption consequential to classification under Heading 84.24 was available.

Analysis: The relevant classification depended on whether the goods were manufactured with the intention of being used, and were in fact supplied, as component parts of irrigation systems. Note 4 to Section XVI treats individual components intended to contribute together to a clearly defined function as classifiable under the heading appropriate to that function. Note 5 does not exclude components merely because they are not machines by themselves. The pipes and fittings in question were supplied as a package for specific irrigation systems, cut to size and assembled on site, and the material on record showed that they were solely used as parts of sprinkler and irrigation systems. On those facts, they contributed directly to the transportation and dispersal function of the irrigation system as a whole.

Conclusion: The goods were classifiable under Heading 84.24 and not under Heading 39.17. The exemption benefit attached to that classification was available, and the duty demand could not be sustained.

Ratio Decidendi: Goods manufactured and supplied as intended component parts of a clearly defined irrigation system are to be classified with the system under the tariff heading for that function, even if the individual components may otherwise answer a separate description.

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