What is chiller
A chiller is
a machine that removes heat from a liquid via a vapor-compression or absorption
refrigeration cycle. This liquid can then be circulated through a heat exchanger to cool air or
equipment as required.
Water chillers
can be water-cooled, air-cooled, or evaporatively cooled. Used in air
conditioning and inindustry. But chiller is not air conditioned system per se
but is a part of air conditioned system.
YORK, YCIVR134a, as per product catalogue, are air
cooled chillers and are designed for water or glycol cooling.The chiller consists of
2 or 3 screw compressors in anCorresponding number of separate refrigerant
circuits, a single shell and tube DX evaporator, an air-cooled condenser, flash
tanks, drain/feed valves, oil separators, and compressor mufflers. Oil
separators utilize no moving parts and are rated for a 31.0 barg (450 psig) design
working pressure. Oil cooling is accomplished by routing oil from the oil
separator through several rows of tubes in the air cooled condenser.An integral
liquid cooled, transistorized, PWM, Variable Speed Drive (VSD) is controlled by
the chiller microprocessor control panel to start/stop, select compressors to
run, and select compressor speed.The chiller is designed to operate in ambient
temperatures of -18°C to 52°C (0°F to 125°).
Air Cooled Water Chillers – How They Work
Air cooled water
chillers are vapour compression refrigeration systems. The main components of a
vapour compression refrigeration system are the compressor, condenser,
expansion valve & evaporator.
Vapour compression
refrigeration systems have a refrigeration cycle. The cycle starts with a cool
low pressure mixture of liquid &vapour refrigerant entering the chiller
evaporator. Once inside the chiller evaporator it absorbs the heat from the
relatively warm water or fluid that the fluid chiller is cooling. This transfer
of heat boils the liquid refrigerant in the chillers evaporator and the
super-heated vapour is pulled into the chillers compressor.
The chillers compressor
compresses the refrigerant to a high temperature & pressure, high enough to
allow the chillers condenser to give up its heat to the cooler ambient air.
Within the chillers condenser, heat is transferred from the hot refrigerant to
the relatively cool ambient air this reduction in the chillers refrigerant
causes it to de-superheat and condense into a liquid, then further sub-cool
before leaving the chiller condenser.
The high pressure
liquid refrigerant then enters the chiller expansion valve causing a large
pressure drop across the chillers refrigerant circuit. The pressure reduction
causes a small portion of the refrigerant to boil off, or flash, this would be
seen in the chillers site glass. The site glass indicates if the chiller is
short of gas, if the chiller is short of refrigerant gas the flashing inside
the chillers site glass will increase. The boiled off refrigerant helps cool
the remaining refrigerant to the desired temperature before the mixture enters
the chiller evaporator to start the cycle again.
9.Under General Rule
of Interpretation (GRI) 1, Customs Tariff Act 1975, goods are to be classified
according to the terms of the headings and any relative section or chapter
notes, and provided the headings or notes do not require otherwise, according
to GRIs 2 through 6.
Section XVI, Note 2, governs the classification
of goods that are identifiable as parts of machines or apparatus of Chapter 84
or Chapter 85. Parts which are goods included in any of the headings of
Chapters 84 and 85 are in all cases to be classified in their respective
headings as per Note 2(a).
Note4 to Section
XVIare for classification of machines based on function which they perform: “Where a machine
(including a combination of machines) consists of individual components
(whether separate or interconnected by piping, by transmission devices, by electric
cablesor by other devices) intended to contribute together to a clearly defined
function covered by one of the headings in Chapter 84 or Chapter 85, then the
whole falls to be classified in the heading appropriate to that function”.
The chiller is mainly consisting of compressor (used to increase the
pressure & temperature of the refrigerant vapour),evaporators (where
cool liquid refrigerant absorbs heat from the chilled water circuit), expansive
valve(used to maintain the pressure difference between the high pressure
& low pressure sides of the chiller system)and condensers (where the
refrigerant vapour is converted to liquid as it rejects heat).
This continuous usesof
refrigeration cycle by chillerfor compression, evaporation and condensation of
refrigerant is used to chill water. It does not perform any function other than
chilling /refrigerating water.Thus Chiller is a refrigeration unit. Hence,
as per note 4 to section XVI, chiller as functional unit has to be classified
as refrigeration system of tariff heading 8418.
Explanatory
Notes to the H.S.N., as per page XVI-8415-1, 2007 edition, which say that
Heading 8415 applies only to machines - (1) equipped with motor-driven fan or
blower, (2) designed to change both the temperature (a heating or cooling
element or both) and the humidity ( a humidifying or drying element or both) of
air; and (3) for which the elements mentioned in (1) and (2) are presented
together.
In the present case, the chiller does not
comprise any motor driven fan or has any facility for changing the humidity
which cannot be controlled/regulated by it. Hence, Chiller does not satisfy all
three conditions to be called a machine falling under heading 8415. Thus
Chiller is not an air-conditioning machine as per HSN explanatory notes to
heading 8415.
That while an imported chiller ,is not an
incomplete or unfinished air conditioning machine of heading 8415.But it is
still a part of air-conditioning system under
that heading.
.Explanatory Notes
to Section XVI, for classification of parts, as per page XVI-2, 2007 edition,
is as under:-
Note 2(a) to Section XVI –
“2. Subject to Note 1 to this Section, Note 1 to Chapter 84 and to Note 1 to Chapter 85, parts of machines (not being parts of the articles of heading 8484, 8544, 8545, 8546 or 8547) are to be classified according to the following rules :
“2. Subject to Note 1 to this Section, Note 1 to Chapter 84 and to Note 1 to Chapter 85, parts of machines (not being parts of the articles of heading 8484, 8544, 8545, 8546 or 8547) are to be classified according to the following rules :
(a) parts
which are goods included in any of the headings of Chapter 84 or 85 (other than
headings 8409, 8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 8538 and 8548)
are in all cases to be classified in their respective headings”;
Exclusion to the
heading (8415 ),as per page XVI-8415-3, 2007 edition, : “……(b) Non-reversible
heat pump of heading 84.18 and chillers for air-conditioning machining (heading
84.18)”.
The Explanatory notes to heading 8415 provides
exclusion from this heading for Chillers for air-conditioning machines
and same are classified into heading84.18
Explanatory Notes toheading 8418, as
per page XVI-8418-3, 2007 edition, states that:”…Apparatus of the foregoing
kinds are classified in this heading if in the following forms:
1) Units comprising a compressor
(with or without motor) and condenser mounted on a common base, whether or not
complete with evaporator, or self-contained absorbing units ( These units are
commonly fitted into domestic type refrigerator or other refrigerating cabinets.)Certain
compression type machines, known as “liquid -cooling units”, combine on a
common base ( with or without condensers) ,compressors and a heat exchanger
containing an evaporator and tubing carrying the liquid to be cooled. These
latter machines include those known as chillers, which are used in air-conditioning
systems”.
Therefore, as per above explanatory notes, chillers
are goodsand specifically covered under tariff heading 8418.
That the language of
the notes to heading 8415 reads for parts, as per page XVI-8415-3, 2007
edition, “If presented as separate elements, the components of air conditioning
machines are classified in accordance with the provisions of Note (2) (a) to
Section XVI (headings 84.14, 84.18, 84.19, 84.21, 84.79, etc.) whether or not
they are designed for building into a self-contained unit.”
But,
because the chiller is also a goods included in heading 8418, it must be
classified in that heading under the authority of Section XVI, Note 2(a).
Thus,
separately presented chillers for air-conditioning machines are classified
under heading 8418 in accordance with note 2(a) to Section XVI and the language
of the notes to heading 8415.
We rely on following case laws where chiller
is classified under tariff heading 8418:
i)Commissioner Of Customs Kochivs M/S Lakeshore
Hospital & Research ... on 21 March, 2001,
ii)Indian Hotels Limited vs Commissioner Of
Customs on 25 April, 2001
Customs, Excise and Gold Tribunal - Tamil Nadu(
2001 (134) ELT 451 Tri Chennai)
iii)COMMISSIONER OF CENTRAL EXCISE, DELHI V.
CARRIER AIRCON LTD [2006] RD-SC 374 (5 July 2006)
Honourablethe
Supreme Court ,held in case of Commissioner
of Central Excise, Delhi v. Carrier Aircon ltd [2006] rd-sc 374 (5
july 2006) thattariff heading 84.15 covers air-conditioning machines which
control and maintain temperature and humidity in closed places, the main
function of air-conditioning system is to control temperature, which is not
done by a chiller. The chillers in question shall fall under specific heading
84.18 of the Tariff Act. This view is supported by the explanatory notes of
H.S.N. below heading 84.15.
Also,Chillers
in the domestic and international trade parlance are known as refrigerating
equipment. The trade identifies chillers as refrigerating machinery on the
basis of its function of chilling water using refrigerating circuit. Even by
testing it from the commercial parlance test as well the chillers would not be
classifiable under Chapter Heading 84.15.
.Honourable Tribunal – Bangalore ,have upheld the classification
of similar ''York refrigeration chiller, under 8418, after considering the HSN
notes, Board's instruction Nos. 242/76/96/CX dated 3.9.96 and have ruled 0ut
the classification under 8415 of the Customs Tariff, in case of Commissioner Of Customs Kochi vs M/S
Lakeshore Hospital & Research ... on 21 March, 2001 . The Tribunal statedthat:
“ After considering the material we find:
(a)
there is no doubt about the item under import being 'liquid chillers' and that
very low temperature could be achieved. Therefore the items to our mind are
functionally designed to produce chilled water (liquid) by using a
refrigeration circuit in it's construction and such chilled liquid, in turn was
applied in an Industrial process, which could be a Central Air Conditioning
System/Plant of a huge size or would be an end use as recorded by the learned
Dy Commissioner, as follows:
"....
The end uses known to the appellants for the said machine are for processing
cooling, brine machine cooling, process cooling for injection Moulding Machine,
CNC Machine cooling, Brine chilling, Chilling of chemical plant and cooling of
rubber and allied products."
We
also find, that the Commissioner (Appeals) has also come to a finding that:
"The
liquid Chiller here is a machine on a common basis with water cooled condenser,
compressor and a heat exchanger containing an evaporator and a tubing carrying
the liquid to be cooled and the combined function of the machine is to cool the
liquid water passing through the tube to the desired temperature which in turn
can be used for other application including air-conditioning with the help of
another independent machine viz. AHU. There is no dispute that the liquid
chiller is used by the importer in this case for chilling the water to 8(SIC)C
for the purpose of using various AHU installed in many locations of the
multi-storey hospital. The brocure/manual and manufacturers clarifications makes
it clear that these apparatus can be used for very low temperature brine
applications also."
(b)
We find that after considering all the case law on the subject, the Tribunal in
the case of Carrier Aircon Ltd., Vs CCE, Delhi-III (2001(128)/EIT/485) have upheld
the classification of similar 'liquid chillers' under 8418, after considering
the HSN notes, Board's instruction Nos. 242/76/96/CX dated 3.9.96 and have
ruled cut the classification under 8415 of the Central Excise Tariff.
(c)
We find that the Central Excise Tariff and the Customs Tariff, is para-materia
as far as headings 8415 and 8418 are concerned. Therefore, relying on this
decision of the Tribunal in Carrier Aircon (2001 (128) EIT 485), we have no
reasons to uphold the revenues appeal to classify the subject goods under
import under 8415”.
That Chiller is a refrigeration
unit .It is a part of air-condition system but in nature of goods. Hence, as
per note 4 to section XVI, chiller as functional unit is to be classified as
refrigeration system of tariff heading 8418.That explanatory notes to Chapter
8415 covering air conditioning machines, states that the heading is
restrictive.
Heading 8415.00 of the
Tariff provides that air-conditioning machines must comprise a motor-driven fan
and elements for changing temperature and humidity. It includes those machines
in which the humidity cannot be separately regulated. Nevertheless, while a
chiller, imported without fans, is not an incomplete or unfinished air conditioning
machine of heading 8415, it is still a part under that heading. But, because
the chiller is also a good included in heading 8418, it must be classified in
that heading under the authority of Section XVI, Note 2(a).
Thus, separately
presented chillers for air-conditioning machines are classified under heading
8418 in accordance with note 2(a) to Section XVI and the language of the notes
to heading 8415.
The Explanatory notes to
heading 8415 provides exclusion from this heading for Chillers for air-conditioning
machines and same are classified into heading 84.18.Therefore, as per explanatory notes to heading 8418, chillers
are specifically covered under tariff heading 8418.
The Chiller does not satisfy all three
conditions to be called a machine falling under heading 8415. Thus Chiller is
not an air-conditioning machine as per HSN explanatory notes to heading 8415..
Honourable Supreme Court
held in case of Commissioner of Central Excise, Delhi v. Carrier Aircon ltd
[2006] rd-sc 374 (5 july 2006) that the chillers in question shall fall under
specific heading 84.18 of the Tariff Act. This view is supported by the
explanatory notes of H.S.N. below heading 84.15. Similarly various Tribunals
also classified chiller under heading 8418 of Customs Tariff.
Also, Chillers in
the domestic and international trade parlance are known as refrigerating
equipment and not as air-conditioning machine.
Under the authority of GIR 1, chiller is
provided for specific heading 8418 .It is classifiable in subheading 84181010.
Therefore, on application of General Rules for the
Interpretation (GIR) of the First Schedule to Customs Tariff GIR-1 read with
Chapter Note 2 (b) and Note 4 to Section
XVI , Chiller falls
under Chapter heading 8418 . Also, as per GIR-6 read with HSN Explanatory Note to tariff heading 8415
& 8418 ‘ Chiller’ is correctly classifiable under tariff heading 84181010.