Disassembled imports may be classified as a complete machine if they form one integrated system on assembly.

Imported goods shipped as separate parts may still be classified as a complete machine if, when assembled, they form one integrated system. The authorities had relied on separate invoice values without first determining that basic factual and classificatory issue. The classification question was therefore remanded for fresh adjudication by a speaking order, with an opportunity for hearing and additional evidence. The possible application of any exemption notification was not decided and was left open.

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Issues: Whether the imported goods, though brought in as separate parts with separate invoice values, were required to be treated as a complete machine for customs classification, and whether the matter required reconsideration by the original adjudicating authority.

Analysis: The goods were claimed to constitute a complete process plant which had been disassembled only for importation. The authorities below proceeded mainly on the footing that the invoice showed separate values for the constituent parts, without first determining whether the imported items, when assembled, formed a complete system. Where disassembled components together constitute a complete machine, classification has to be made according to the tariff heading appropriate to the whole machine. At the same time, the question whether such classification would also extend the benefit of the exemption notification was left open. As the basic factual and classificatory issue had not been examined, fresh determination was necessary.

Conclusion: The matter was remanded to the original adjudicating authority for de novo decision by a speaking order on classification of the goods, after giving the appellants an opportunity of hearing and to produce additional evidence.

Final Conclusion: The classification dispute was not finally decided on merits and was sent back for fresh adjudication on the core question whether the imported components constituted a complete machine.

Ratio Decidendi: If imported goods, though shipped in disassembled form, constitute a complete machine when assembled, they must be classified under the tariff heading applicable to the whole machine after examining that basic factual issue.

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