Classification of VRF air-conditioner units as parts under Heading 8415 9000 upheld over split system classification.

Imported indoor and outdoor VRF air-conditioner units were held classifiable as parts under Heading 8415 9000, not as split system air conditioners under Heading 8415 1010. The purchase orders, model details and surrounding records showed the goods were VRF units, and the absence of an express VRF reference in the import documents was not decisive. Because the imports did not include the other essential components needed to make a complete split system, the department's contrary classification was rejected. Prior decisions treating similar VRF indoor and outdoor units as parts under Heading 8415 9000 were followed, and the department's classification was found unsustainable.

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Issues: Whether imported indoor and outdoor units of VRF air conditioners were classifiable as parts under Heading 8415 9000 of the Customs Tariff Act, 1975, or as split system air conditioners under Heading 8415 1010, and whether the notification benefit was available.

Analysis: The imports consisted only of indoor and outdoor units. The purchase orders and model details established that the goods were of VRF technology. The record showed that essential components required to make a complete split system, including other crucial installation parts, were not imported. The classification adopted by the department was rejected because the absence of any mention of VRF technology in the import documents was not decisive when the purchase orders and surrounding material showed the true nature of the goods. Reliance was also placed on prior decisions treating similar indoor and outdoor units of VRF systems as parts classifiable under Heading 8415 9000.

Conclusion: The imported goods were correctly classifiable under Heading 8415 9000 as parts of air conditioners, and the department's contrary classification was unsustainable.

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