Customs tariff classification of imported multi-function printers/copiers: treated as ADP input-output units under Heading 84.71.60, not 84.79.89.

The dominant issue was the correct customs tariff classification of imported multi-functional machines (duplicating, printing, and related functions). The SC held that these goods were appropriately classifiable under Customs Tariff Heading 84.71.60 as input-output units, on the basis that their principal character and functional integration aligned with units used in automatic data processing systems rather than being "other machines" falling in a residuary category. Consequently, classification under the residuary Heading 84.79.89 was rejected, and the goods were directed to be assessed under Heading 84.71.60.

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Issues: Whether the imported Multi-Functional Machines (Xerox Regal 5799, Xerox Workcentre XD100 and XD155df) are classifiable under Customs Tariff heading 84.71.60 (units/inputs-outputs of automatic data processing machines) or under the residuary heading 84.79.89.

Analysis: The Court examined the relevant tariff headings, Chapter Note 5 to Chapter 84, Rule 3(a) and 3(b) of the General Rules for interpretation, and Note 3 of Section XVI. The factual finding that the machines have a predominant printing component (about 85% for one model and 74% for another) establishes that the printing function is the principal function and gives the machines their essential character under Rule 3(b) and Note 3 Section XVI. The Court applied the three-fold test in Chapter Note 5(B): (a) the machines are of a kind principally used in an automatic data processing system; (b) they are connectable to a central processing unit; and (c) they accept and deliver data in a form usable by the system. Chapter Note 5(D) further supports classification of printers (and devices meeting 5(B)(b) and 5(B)(c)) as units of heading 84.71. The Court rejected the Revenue's reliance on Chapter Note 5(E) because the machines are presented independently and their principal function is printing, not merely machines performing a specific non-data-processing function working in conjunction with an ADPM. Applying Rule 3(a) (preference for the more specific heading) together with the chapter notes, the Court concluded that the Multi-Functional Machines qualify as units/inputs-outputs of ADPMs and fall under sub-heading 84.71.60 rather than the residual heading 84.79.89.

Conclusion: The imported Multi-Functional Machines are classifiable under Customs Tariff heading 84.71.60. The appeal is allowed and the Tribunal's order is set aside. Parties to bear their own costs.

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