Tariff classification of a dual-use grinding machine excluded from Heading 84.56 because it was designed for chemicals too

A grinding machine designed for both minerals and chemicals was excluded from Tariff Heading 84.56 because that heading applies mainly to machinery used for mineral substances in extractive industries. The Explanatory Notes indicate that machinery specially designed for grinding or mixing chemicals falls outside the heading, and reliance on Rule 2 of the Interpretative Rules was misplaced on these facts. The machine was therefore not classifiable under Heading 84.56.

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Issues: Whether the imported grinding machine was classifiable under Tariff Heading 84.56 of the Customs Tariff Act, 1975.

Analysis: Tariff Heading 84.56 covers machinery used mainly in extractive industries for sorting, screening, separating, washing, crushing, grinding or mixing earth, stones, ores or other mineral substances in solid form. The Explanatory Notes show that machinery specially designed for grinding or mixing chemicals is outside that heading. On the facts, the machine was designed for grinding both minerals and chemicals, and the lower appellate authority's reliance on Rule 2 of the Interpretative Rules of the Customs Tariff was held to be misplaced.

Conclusion: The machine was not classifiable under Tariff Heading 84.56.

Ratio Decidendi: A machine specially designed for grinding or mixing chemicals, even if also capable of grinding minerals, is excluded from Tariff Heading 84.56 when the tariff heading is confined to machinery used mainly for mineral substances.

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