Specific tariff heading prevails in customs classification of electrostatic precipitator components

Imported components for manufacturing electrostatic precipitators were classified under Heading 84.18(1) of the Customs Tariff Act because that entry specifically covered the goods. The SC held that the materials did not fall within Heading 84.01/02 or 84.17(1), and could not be retained under the broader residual limb of Heading 84.18(2). Applying the settled rule that a specific tariff description prevails over less apt general headings, the Court accepted the assessee's classification and rejected the competing entries.

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Issues: Whether the imported components for manufacturing electrostatic precipitators were classifiable under Heading 84.18(1) of the Customs Tariff Act, 1975, rather than under Headings 84.18(2), 84.17(1) or 84.01/02.

Analysis: The imported goods were examined in the light of the competing tariff entries. The goods did not answer the description of Heading 84.01/02 or Heading 84.17(1). Heading 84.18 was the more specific entry covering electrostatic precipitators, and within that heading the correct classification was 84.18(1). A specific and explicit tariff entry must prevail over less apt general headings, and the materials imported for electrostatic precipitators could not properly be retained under Heading 84.18(2).

Conclusion: The goods were held to be classifiable under Heading 84.18(1), and the assessee succeeded on the classification issue.

Ratio Decidendi: For tariff classification, the more specific entry describing the goods must prevail over broader or less apt competing headings.

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