Specific use over material description governs classification of mushroom growing racks as agricultural machinery, not aluminium structures.

Imported mushroom growing shelving and racks were classified by applying the General Rules for Interpretation, with preference given to the heading providing the most specific description. Although Chapter 76 covers aluminium structures, the goods were specially designed for mushroom cultivation and integrated only with the agricultural growing system. Their trade description, design, and functional use supported classification as agricultural machinery under CTH 84369900 rather than as aluminium structures under CTH 76109010. The misclassification-based demand therefore could not stand, and the appellant succeeded.

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Issues: Whether mushroom growing shelving or racks imported for use with drainage and watering systems were classifiable under CTH 84369900 as agricultural machinery or under CTH 76109010 as aluminium structures.

Analysis: Classification had to be determined by the General Rules for Interpretation, with Rule 1 and Rule 3 requiring preference for the heading giving the most specific description. Chapter 76 is a general heading for aluminium structures, while Chapter 84 covers machinery and mechanical appliances for agricultural use. The imported goods were specially designed for mushroom cultivation, were intended to function only as part of the mushroom growing system, and were not shown to have any general utility as ordinary aluminium structures. The trade description, design, and functional integration with agricultural equipment supported classification by their specific end use rather than by their material alone.

Conclusion: The goods were correctly classifiable under CTH 84369900 and not under CTH 76109010. The demand based on misclassification could not survive and the appellant succeeded.

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