Heat pump classification under Chapter 84.18 prevails where air-conditioning components required for Heading 84.15 are not shown.

Liquid brine evaporators described as heat pumps were treated as classifiable under Chapter Heading 84.18, because Heading 84.15 applies only to air-conditioning machines equipped with a motor-driven fan or blower and elements for changing both heat and humidity. The Revenue did not establish that the goods contained the components or functions required for Heading 84.15. The objection that the product was actually a lithium bromide absorption system was rejected, as the essential nature of a heat pump does not change with the medium used. Later use with additions or modifications in air-conditioning equipment did not alter classification of the goods as cleared, so the Revenue's challenge failed.

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Issues: Whether the liquid brine evaporator described as a heat pump was classifiable under Chapter Heading 84.18 as a refrigerating or freezing machine or under Chapter Heading 84.15 as an air-conditioning machine.

Analysis: Chapter Heading 84.15 applies only to air-conditioning machines equipped with a motor-driven fan or blower and elements for changing both heat and humidity. The product was found not to satisfy these requirements, and the Revenue did not establish the presence of the components necessary to bring it within that heading. The objection that the goods were not a heat pump but a lithium bromide absorption system was rejected, as the basic nature of a heat pump does not change with the medium used. The fact that the goods may be used with additions or modifications in air-conditioning equipment did not alter the classification of the goods as cleared. Reliance was also placed on prior Tribunal decisions classifying the same product under Heading 84.18.

Conclusion: The product was held classifiable under Chapter Heading 84.18 and not under Chapter Heading 84.15, so the Revenue's appeal failed.

Ratio Decidendi: A heat pump is classifiable under Chapter Heading 84.18 unless it is shown to possess the specific components and functions that bring it within the scope of Chapter Heading 84.15 as an air-conditioning machine; later or modified use in air-conditioning does not change the tariff classification of the goods as cleared.

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