Off-road design governs tyre classification for loaders and cranes, not actual use, under the applicable tariff entry.

Tyres fitted to mechanically propelled front-end loaders and cranes used as material handling equipment were classifiable under the tariff entry for tyres for vehicles or equipment designed for use off the road. The decisive factor was the design of the vehicle or equipment for off-road use, not its actual manner of use. The narrower reading that "equipment" should be confined in a limited sense was rejected, and the tyres were therefore excluded from the general entry for all other tyres.

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Issues: Whether tyres for front-end loaders and cranes were classifiable under Tariff Item 16-III as all other tyres, or under Tariff Item 16-I(i) as tyres for vehicles or equipment designed for use off the road.

Analysis: The tyres in question were for mechanically propelled front-end loaders and cranes used as material handling equipment. The decisive feature under Tariff Item 16-I(i) was the design of the vehicle or equipment for off-road use, not the actual manner of use. Since the loaders and cranes were found to be equipment designed for use off the road, the tyres fell within Tariff Item 16-I(i). The broader contention that the expression "equipment" should be narrowly confined was rejected.

Conclusion: The tyres were correctly classifiable under Tariff Item 16-I(i) and not under Tariff Item 16-III.

Ratio Decidendi: Where a tariff entry turns on equipment designed for use off the road, classification depends on the design of the equipment and not on its actual use.

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