Exemption for water filters turns on specified storage capacity; continuous flow purifier without holding capacity was outside the notification.

A continuous flow water purifier installed on a pipeline, without any storage or holding capacity, did not satisfy exemption notifications limited to water filters of capacity not exceeding 40 litres. The notifications were construed as covering only filters of the specified configuration in which water is stored after filtration and then drawn for use. Because the product lacked the capacity parameter expressly built into the exemption, the language of the notifications could not be expanded by reference to domestic use or a liberal reading that would override the stated limit. The exemption claim therefore failed.

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Issues: Whether a continuous flow water purifier fitted on a water pipeline, without storage capacity, qualified for exemption under the notifications applicable to water filters of capacity not exceeding 40 litres.

Analysis: The exemption notifications identified a specific category of water filters by reference to their storage capacity and contemplated filters of a particular configuration in which water is held and then drawn after filtration. The product in question operated as a continuous purification device, had no holding or storage capacity, and could not satisfy the capacity parameter embedded in the notifications. Once the exempted product is identified by specific parameters, those parameters must be applied as written and cannot be expanded by resort to general domestic use or to a liberal interpretation that overrides the express limitation.

Conclusion: The product did not fall within the exemption notifications and the claim for exemption failed.

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