Tariff classification of integrated design system with knitting machine follows common-function test, not separate invoicing.

Imported Graphic Design System used only with a Jacquard Flat Knitting Machine was treated as part of the machine combination under Note 4 to Section XVI because the components worked together for one clearly defined function and the system had no independent utility. Separate invoicing did not change its essential character or create a separate commercial identity for tariff classification. The item was therefore classifiable with the knitting machine rather than as an independent automatic data processing machine under Heading 84.71, and the impugned order was set aside.

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Issues: Whether the imported Graphic Design System, used with the Jacquard Flat Knitting Machine, was classifiable as part of the knitting machine under Heading 84.47 or as an independent automatic data processing machine under Heading 84.71, and whether the benefit of exemption could be denied on the basis of separate invoicing.

Analysis: The classification turned on whether the imported components together constituted a machine designed to contribute to one clearly defined function. Note 4 to Section XVI governs combinations of machines consisting of separate components intended to work together for a common function, in which case the whole is classified in the heading appropriate to that function. The imported Graphic Design System was found to work only with the Jacquard Flat Knitting Machine and there was no evidence that it had independent utility or could be used elsewhere. The fact that the items were separately invoiced was held not to alter their essential character, since separate invoicing does not by itself establish separate commercial identity for classification purposes. The reasoning was supported by the treatment of interconnected components under the tariff notes and the conclusion that the graphic design workstation formed part of the machine system for weaving or knitting designs.

Conclusion: The Graphic Design System was held classifiable with the Jacquard Flat Knitting Machine and not as an independent computer under Heading 84.71; the impugned order was set aside and the appeal was allowed.

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