Tariff classification of lamp components turned on specificity, with tungsten wires and lead-in-wires treated as metal articles

Imported tungsten filament wires for use in electric filament lamps were classified under the tariff heading for tungsten and articles thereof because they required further processing and that specific entry prevailed over the more general lamp-parts heading. Lead-in-wires, composed of fused metal sections with nickel predominating by weight and needing substantial processing before fitment, were classified as articles of nickel rather than as parts of electric filament lamps. The classification claimed under lamp parts was rejected for both goods, with tariff notes and interpretative principles applied to prefer the more specific descriptions.

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Issues: Whether lead-in-wires and tungsten filament wires imported for use in electric filament lamps were classifiable under the tariff headings for nickel articles and tungsten articles, or under the heading for parts of electric filament lamps.

Analysis: The tungsten filament wires required further processing before they could be used in lamps and were specifically covered by the tariff entry for tungsten and articles thereof. That entry was more specific than the heading for electric filament lamps, and the specific entry prevailed over the general. As regards lead-in-wires, the evidence showed that they were made of two or more fused metal sections with nickel predominating by weight, and they too required substantial processing, including degassing and encapsulating in glass, before fitment. Applying the tariff notes and the interpretative principles, the goods were better described as articles of nickel rather than as parts of lamps.

Conclusion: The classification under the heading for electric filament lamp parts was rejected. Tungsten filament wires were held classifiable under the heading for tungsten and articles thereof, and lead-in-wires were held classifiable under the heading for nickel and articles thereof.

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