Tariff classification of bulk milk cooling tanks turns on refrigerating function at the active cooling element, not stored product temperature.

The Bulk Milk Cooling Tank was held to fall under Chapter Heading 8418.10 because its cooling coil generated ice and ice water through a refrigerating process at the active cooling element. The relevant classification test was the function of the machinery at that active element, not merely the temperature maintained in the stored milk. Relying on the HSN explanatory notes, which treat refrigerating equipment as machinery producing low temperatures at the active cooling element, the system was found to have a refrigerating function rather than a mere cooling function. It was therefore classifiable under Chapter Heading 8418.10 and not under Chapter Heading 8419.10.

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Issues: Whether the Bulk Milk Cooling Tank was correctly classifiable under Chapter Heading 8418.10 as refrigerating equipment or under Chapter Heading 8419.10 as a cooling appliance.

Analysis: The product consisted of a milk vessel, ice water vessel, cooling coil and condensing unit, and the cooling coil generated ice which in turn produced ice water for cooling the milk. The temperature maintained in the milk was around 4 C, but the relevant consideration was the temperature at the active cooling element, not merely the temperature of the product stored. The explanatory notes to the Harmonised System of Nomenclature treated refrigerating equipment as machinery producing low temperatures at the active cooling element, and those notes were a reliable guide to tariff classification. On that basis, the system was found to have a refrigerating function and not merely a general cooling function.

Conclusion: The Bulk Milk Cooling Tank was correctly classifiable under Chapter Heading 8418.10, and not under Chapter Heading 8419.10.

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