Classification of air handling units as parts of air-conditioning machines upheld under principal-use rule

Air handling unit goods manufactured as components for central air-conditioning systems were classifiable as parts of air-conditioning machines under Heading 84.15, not as air or gas compressors, pumps or fans under Heading 84.14. Applying Section Note 2(b) of Section XVI, goods suitable for use solely or principally with a particular machine must be classified with that machine. Because the units were specially designed for principal use in air-conditioning plants and supplied to air-conditioner manufacturers, their proper classification followed the machine with which they were intended to work. The departmental classification under Heading 84.15 was therefore upheld.

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Issues: Whether the Air Handling Unit goods were classifiable under Heading 84.14 as air or vacuum pumps, air or other gas compressors and fans, or under Heading 84.15 as parts of air conditioning machines.

Analysis: The goods were manufactured as components for central air-conditioning systems and were supplied to air-conditioner manufacturers. Their construction showed that they were not fans, pumps or compressors within Heading 84.14, but specialised units intended for use with air-conditioning machines. Under Section Note 2(b) of Section XVI, parts suitable for use solely or principally with a particular kind of machine are to be classified with that machine. Since the goods were admittedly designed for principal use in air-conditioning plants, the proper classification was with air-conditioning machines under Heading 84.15.

Conclusion: The classification under Heading 84.15 was correct and the assessee's claim to Heading 84.14 failed.

Final Conclusion: The appeal was rejected and the departmental classification was upheld.

Ratio Decidendi: Goods that are parts suitable for use solely or principally with a particular machine must be classified with that machine, even if they may have other possible uses.

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