Specific tariff classification controls composite bottling machinery, defeating residuary customs classification for an integrated aerated beverages line.

An integrated coating machine used in an aerated beverages bottling line was treated as part of composite machinery for bottling and aerating beverages, because its function was incidental to the line and not an independent principal function. Chapter 84 classification had to follow the specific heading covering machinery for filling, closing, sealing, labelling and aerating beverages, rather than the residuary heading for machines not specified elsewhere. The goods were therefore classifiable under tariff item 8422 30 00, with parts under 8422 90 90, and the contrary customs demand, confiscation and penalties based on tariff item 8479 89 99 were unsustainable.

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Issues: Whether the imported coating machine used in an aerated beverages bottling line was classifiable under tariff item 8422 30 00 as machinery for aerating beverages, or under tariff item 8479 89 99 as machinery having individual functions not specified elsewhere, and whether the resulting customs demand, confiscation and penalties were sustainable.

Analysis: The tariff scheme under Chapter 84, the General Rules for Interpretation, and Section XVI Notes 3, 4 and 5 require classification by the terms of the heading, the relevant section and chapter notes, and the principal function of composite machinery. Heading 8422 specifically covers machinery for filling, closing, sealing, labelling and aerating beverages, while heading 8479 is residuary and applies only to machines not more specifically covered elsewhere in Chapter 84. The imported machine formed part of an integrated bottling line for PET bottles and aerated beverages, working in tandem with the blow moulding and filling equipment. Its coating function was incidental to the composite bottling process and did not make it an independent machine with a separate principal function. The HSN explanatory notes to heading 8422 support inclusion of machinery used in bottling and aerating beverages, whereas heading 8479 does not fit the nature of the goods. The residuary classification proposed by Revenue was therefore impermissible when a specific entry covered the goods.

Conclusion: The imported machine was correctly classifiable under tariff item 8422 30 00, and its parts under tariff item 8422 90 90, not under tariff item 8479 89 99. The customs demand, confiscation and penalties founded on the contrary classification were not sustainable.

Final Conclusion: The classification adopted by the appellants was upheld, and the impugned adjudication was set aside.

Ratio Decidendi: Where a machine forms an integrated part of a composite bottling line and a specific tariff entry covers its function, it must be classified under that specific entry and not under a residuary heading merely because it may perform an ancillary or technologically advanced process.

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