Principal purpose test governs classification of a multipurpose homogenizer under the Customs Tariff scheme.

Import classification of a multipurpose Gaulin-3 plunger high process homogenizer turned on the tariff heading terms and Chapter 84 notes. For machines capable of more than one use, the controlling test was principal purpose or main function. Because the equipment was intended for both food processing and dairy processing, and not exclusively for dairy use, Note 2 to Chapter 84 required classification under the food-processing heading. The CCCN explanatory notes were treated as persuasive only and could not override the tariff scheme. The goods were therefore classifiable under Item 84.17(2) and not under Item 84.26.

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Issues: Whether the imported Gaulin-3 Plunger High Process Homogenizer was classifiable under Item 84.17(2) of the Customs Tariff Act, 1975 or under Item 84.26 of the Customs Tariff Act, 1975.

Analysis: Classification was to be determined in accordance with the tariff heading terms and the relevant section and chapter notes. For multipurpose machines, the governing principle was that they are classified according to their principal purpose or main function. The equipment in question was found to be meant for both food processing and dairy processing, and not exclusively for dairy use. The explanatory notes to the CCCN could have only persuasive value and could not override the tariff scheme. Since the machine answered both the food-processing heading and the dairy-machinery heading, Note 2 to Chapter 84 required classification under the former heading.

Conclusion: The goods were correctly classifiable under Item 84.17(2) and not under Item 84.26.

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