Heavy-duty mobile crane classification favours crane heading over special-purpose vehicle heading under the Customs Tariff.

A specially designed heavy-duty mobile crane mounted on a chassis was classified under Tariff Heading 84.26 rather than Heading 87.05. Applying the HSN notes as interpretive guidance, the classification turned on whether the goods answered the description of ordinary cranes or light breakdown cranes mounted on automobile chassis or lorries. On the facts, the equipment had a collapsible boom, lifting capability to great heights, and a heavy-duty 16-wheel chassis that was not shown to be a lorry-like special-purpose motor vehicle. The appeal succeeded and consequential relief followed.

---

---

Issues: Whether the imported 90-tonne crane mounted on a chassis was classifiable under Tariff Heading 87.05 or Tariff Heading 84.26.

Analysis: The Customs Tariff being based on the HSN, the HSN notes were treated as relevant for interpretation. Heading 87.05 was read as covering ordinary cranes or light breakdown cranes mounted on automobile chassis or lorries. On the facts, the imported equipment was a specially designed heavy-duty crane with collapsible boom, capable of lifting loads to great heights, and its chassis with 16 wheels and heavy-duty axles was not shown to be a lorry for classification purposes. The goods were therefore held not to answer the description of ordinary cranes or special purpose motor vehicles falling under Heading 87.05.

Conclusion: The crane was classifiable under Tariff Heading 84.26 and not under Tariff Heading 87.05.

Final Conclusion: The appeal succeeded and the assessee obtained consequential relief on the basis that the imported crane fell within the crane heading rather than the special-purpose vehicle heading.

Ratio Decidendi: A specially designed heavy-duty mobile crane mounted on a chassis is classifiable under the crane heading when it is not shown to be an ordinary crane or a lorry-like special purpose motor vehicle covered by the competing vehicle heading.

---