Classification of treated polyimide film turns on essential character, with film entry prevailing over adhesive tape and residuary entries.

Polyimide film bearing the brand name "Kapton", even when given special treatment and converted into tape form, retained its essential character as film and remained classifiable under Tariff Item 15A(2), which covered boards, sheeting, sheets and films whether lacquered, metallised or laminated or not. The treatment did not convert the goods into adhesive tape for Tariff Item 60, and the residuary Tariff Item 68 was inapplicable because a specific entry governed the product. Earlier decisions on similar treated films were followed, while authorities supporting classification under Items 60 or 68 were distinguished.

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Issues: Whether the imported polyimide film bearing the brand name "Kapton", used in tape form and given special treatment, was classifiable for additional duty under Tariff Item 15A(2) as a film of material covered by that item, or under Tariff Item 60 as adhesive tape or Tariff Item 68 as a residuary entry.

Analysis: Tariff Item 15A(2) specifically covered boards, sheeting, sheets and films, whether lacquered, metallised or laminated or not. The goods were not disputed to be polyimide film, and the special treatment or conversion into tape form did not alter their essential character as film. Earlier decisions holding similar treated films classifiable under Tariff Item 15A(2) were preferred, while the authorities relied on for classification under Tariff Item 60 or Tariff Item 68 were treated as distinguishable. Tariff Item 60 was confined to adhesive tapes not elsewhere specified, and the goods, being properly includible under Tariff Item 15A(2), stood excluded from that item.

Conclusion: The goods were correctly classifiable under Tariff Item 15A(2) of the Central Excise Tariff and not under Tariff Item 60 or Tariff Item 68.

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