Import classification of signal decoder turns on whether it is a receiver itself or an essential part of satellite reception equipment.

An imported signal decoder that did not itself receive television signals and was used only between the satellite receiver and the television set to unscramble encrypted signals was classified as a part of the satellite reception system rather than as the reception apparatus itself. The tariff entry for parts suitable for use solely or principally with apparatus of Headings 85.25 to 85.28 was applied, because the decoder functioned as an essential component of the receiver system. Classification under the residual parts heading was accepted, and the item was held classifiable under sub-heading 8529.90, not under sub-heading 8528.12.

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Issues: Whether the imported signal decoder was classifiable under Heading 85.28 as a reception apparatus for television or under Heading 85.29 as a part of satellite reception apparatus.

Analysis: The signal decoder did not itself receive television signals and was used between the satellite receiver and the television set to unscramble or decode encrypted signals. It was therefore not a satellite receiver falling under Heading 85.28. The relevant tariff entry for parts suitable for use solely or principally with apparatus of Headings 85.25 to 85.28 was Heading 85.29. The decoder was treated as an essential part of the satellite receiver system, and the alternative classification under the residual parts heading was accepted.

Conclusion: The imported signal decoder was classifiable under sub-heading 8529.90 of the Customs Tariff Act and not under sub-heading 8528.12; the issue was decided in favour of the assessee.

Ratio Decidendi: Where an imported article does not itself perform the function of the principal apparatus but serves as an essential part of that apparatus, it is classifiable as a part of the apparatus under the relevant parts heading rather than as the apparatus itself.

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