Composite testing equipment exemption extends to an essential recorder treated as part of the main machine.

The Surgraphic Recorder imported with the surface roughness testing equipment was treated as part of the composite machine because the system was ordered and invoiced as a complete unit, supplier correspondence showed the recording facility was essential for precision bearing inspection, and separate pricing was unavailable. The catalogue reference to added versatility did not alter its character where the evidence showed it was necessary for the intended use of the equipment. On that basis, the recorder was not an optional accessory divorced from the machine, and exemption extended with the main instrument; denial of exemption was not sustainable.

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Issues: Whether the Surgraphic Recorder imported along with the surface roughness testing equipment was an integral part of the composite machine and therefore entitled to the same customs exemption as the main equipment, or merely an optional accessory outside the scope of the exemption notification.

Analysis: The imported system was ordered and invoiced as a complete Surtronic 3P composite equipment, and the correspondence from the supplier showed that the recording facility formed an essential part of the system for precision bearing inspection. The record also showed that separate pricing for the recorder was not available and that, for the bearing industry, permanent graphical records were required to locate defects and obtain accurate corrective action. The catalogue reference to increased versatility did not change the character of the recorder where the evidence showed that it was necessary for the intended use of the equipment. In these circumstances, the recorder could not be treated as a detachable optional item divorced from the machine.

Conclusion: The Surgraphic Recorder was part of the composite testing equipment and was eligible for exemption along with the main instrument; the denial of exemption was not sustainable.

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