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of <h1>Imported roller and sorter conveyor units: whether 'parts' (8431) or full conveyors (8428); classified as 84282019</h1> The dominant issue was whether imported roller conveyors and sorter conveyors were classifiable as 'parts' under Heading 8431 or as conveyors under ... Classification of imported Roller Conveyors and Sorter Conveyors - to be classified under CTI 8428 2019 of the First Schedule of the Customs Tariff Act, 1975 or not - HELD THAT:- Heading 8431 of the Customs Tariff is narrowly tailored and pertains exclusively to 'Parts suitable for use solely or principally with the machinery of headings 8425 to 8430.' The legal scope of Heading 8431 is thus confined to articles which, by their nature, function solely or principally as components integral to the operation of machinery classified under those specific headings. In contrast, Roller Conveyors and Sorter Conveyors do not fall within this definition, as they are not merely auxiliary attachments or subordinate mechanical elements. Instead, they are independently operating mechanical devices, purposefully built to execute distinct mechanical functions crucial to the automated movement and sorting of goods. The Explanatory Notes to Heading 8428 issued by the World Customs Organization (WCO), explicitly state that conveyors-including roller conveyors and sorting conveyors-fall within the scope of Heading 8428, irrespective of whether they are designed for continuous or intermittent operation. The WCO Explanatory Notes further clarify that this heading encompasses a broad spectrum of conveyor systems, including mechanical, hydraulic, pneumatic, and other variants, thereby affirming that machinery whose essential function is the movement or sorting of goods is properly classifiable under Heading 8428, provided it operates as a complete mechanical unit. Consequently, when Roller Conveyors and Sorter Conveyors are imported as individual units, they retain their essential character as complete machines designed to execute specific mechanical functions autonomously. They therefore merit classification under Heading 8428 and, more precisely, under Customs Tariff Item (CTI) 84282019 as 'Other conveyors,' rather than under Heading 8431, which is legally reserved for parts suitable for use solely or principally with other machinery. Such classification is fully consistent with the statutory framework of the Customs Tariff, aligns with the technical and commercial attributes of these goods, and upholds the fundamental principle that machinery capable of independent mechanical function is to be classified under the headings that specifically describe such machinery, rather than residual provisions intended for parts or accessories. Thus, roller conveyors and sorter conveyors, when imported separately by the applicant, are correctly classifiable under CTI 84282019 as 'Other conveyors,' in accordance with the General Rules for Interpretation, and consistent jurisprudence, thereby ensuring their appropriate classification under the Indian Customs Tariff. Issues: Whether Roller Conveyors and Sorter Conveyors imported separately are classifiable under CTI 84282019 (Other conveyors) of the First Schedule to the Customs Tariff Act, 1975 or under CTI 84313910 (parts suitable for use solely or principally with machinery of headings 8425 to 8430).Analysis: Classification is to be determined by the terms of the tariff headings and applicable Section or Chapter Notes read with the General Rules for the Interpretation of the Harmonized System. Note 2(a) to Section XVI requires that goods which are machines in their own right be classified in their appropriate headings rather than as parts. Heading 8428 expressly covers conveyors and similar handling machinery, and the WCO Explanatory Notes treat roller conveyors and sorting conveyors as falling within Heading 8428. Heading 8431 is confined to parts suitable solely or principally for machinery of headings 8425 to 8430. The conveyors as described possess driven rollers, motors, diverters, sensors and control systems and perform independent mechanical functions such as conveying, accumulating, tracking and sorting; they are marketed and traded as standalone machines and are not mere subordinate components of other machines.Analysis: Applying the General Rules and the Section and Chapter Notes, the conveyors retain their essential character as complete mechanically driven machines when imported as individual units. The technical features and autonomous operational capability negate classification as parts under Heading 8431 and align the goods with the description of conveyors under Heading 8428 and the residual subheading for other conveyors.Conclusion: Roller Conveyors and Sorter Conveyors imported separately are classifiable under CTI 84282019 (Other conveyors) of the First Schedule to the Customs Tariff Act, 1975 in favour of the applicant.
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