HS/TN VED classification · А53-21428/2024
Rost LLC declared Vinnitsa one- and two-row manual seeders under heading 8201. Customs chose 8432 and required the declaration to be amended before release. The court compared the product's design, source of movement and technical documents, not merely the names of the two headings.Rost LLC imported Vinnitsa one- and two-row manual seeders from Moldova. The company declared heading 8201 for hand tools used in agriculture. On 23 April 2024, the Southern Electronic Customs issued classification decision No. РКТ-10323000-24/000053, classified the goods under heading 8432 as agricultural machinery and required the declaration to be amended before release.
Customs argued that the product had a wheeled seed hopper, metering mechanism, coulter and covering device, elements mentioned in the Explanatory Notes to heading 8432. It also relied on the broad definition of a machine in the Note to Section XVI.
The court did not dispute that those parts were present, but asked whether they were enough to bring the product within heading 8432. The Explanatory Notes also exclude hand planters and similar hand tools, directing them to heading 8201.
Technical comparison
What was compared between headings 8201 and 8432The graphic does not assign a code; it shows the characteristics discussed in the case.operator muscle power and no engine
set of machine elements described in the Explanatory Notes
design, function and method of operation
The expert found that both models were manual precision seeders. Their design had no standard mounting point for an engine. They were operated and controlled by a person without power from an engine. Customs did not put a separate question to the expert asking whether the products examined were agricultural machines.
The courts linked those characteristics to the exclusion in the Explanatory Notes to heading 8432. Manual propulsion was not merely a way to move the product; it was part of its functional design, because the seeder worked only through the operator's muscle power.
From the technical finding
The design has no standard mounting point for an engine; operation and control are performed by a person.
expert opinion as summarized in the court rulings
The Commercial Court of the Rostov Region held the classification decision and the requirement to amend the declaration unlawful and awarded RUB 6,000 in state-fee costs. The appellate court on 7 March 2025 and the cassation court on 22 May 2025 upheld the judgment. On 25 September 2025, the Supreme Court declined to refer customs' cassation appeal for review.
The late-2025 and 2026 rulings shown in this case card concern later allocation of litigation costs. They do not overturn or reconsider the classification outcome.
A court reviews the legality of customs' classification; it does not assign a code to an abstract category of goods. For another model, relevant facts include technical documentation, method of operation, whether it has an engine or mounting point for one, design of the seeding mechanism, completeness on import and the questions put to the expert.
Court rulings
This review concerns the named court ruling. Any other dispute requires a separate check of the document, date, evidence and procedural stage.Original court document linked; this page provides an English explanation, not a certified translation.