Tariff classification of lightning arrester shells turned on specific description prevailing over general parts entry.

Shells used in high-voltage lightning arresters were held classifiable as insulators under sub-heading (1) of Heading 85.18/27, because the tariff specifically described insulators separately from the broader category of parts of apparatus for the protection of electrical circuits. Applying Note 2 to Section XVI and the principle that a specific description prevails over a general one, the goods' ceramic composition and heat-resisting qualities did not change their essential function as electrical insulators. The broader entry for parts of protective electrical apparatus therefore did not apply.

---

---

Issues: Whether the shells used in the assembly of a lightning arrester were classifiable as parts of apparatus for the protection of electrical circuits under sub-heading (3) of Heading 85.18/27 of the Customs Tariff Schedule, or as insulators of any material falling under sub-heading (1) of that heading.

Analysis: The goods were found to be intended for use in high-voltage lightning arresters and could, in a general sense, be regarded as parts of such apparatus. However, the tariff heading itself separately mentioned insulators of any material. Applying Note 2 to Section XVI of the Customs Tariff Schedule and the interpretative rule that classification within a heading is governed by the same principles as classification between headings, the separate and specific description of insulators had to prevail over the broader description of parts of protective electrical apparatus. The special ceramic composition and heat-resisting character of the goods did not alter their essential function as electrical insulators.

Conclusion: The shells were correctly classifiable as insulators under sub-heading (1) of Heading 85.18/27 and not under sub-heading (3).

---