Classification of tungsten metal tips must follow the specific tungsten heading, not the ignition equipment heading, for raw material goods.

Imported tungsten metal tips were held to be raw material rather than identifiable parts of ignition equipment, so classification had to follow the tariff heading specifically covering tungsten articles instead of the heading for electrical starting and ignition equipment. The Customs Tariff Act was interpreted on its own terms, and the record did not support exclusive use in internal combustion engine ignition systems. The goods were therefore classifiable under Heading 81.01/04, not Heading 85.08, with consequential relief including refund if otherwise admissible.

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Issues: Whether tungsten metal tips imported by the assessee were correctly classifiable under Heading 85.08 as electrical starting and ignition equipments for internal combustion engines, or under Heading 81.01(1) as tungsten articles/raw material, and whether refund consequential to reclassification was payable.

Analysis: The imported goods were found to be in the nature of raw material and not identifiable parts of any machine. The relevant tariff note for tungsten under Heading 81.01 showed that tungsten plates used to make electrical contacts would fall within that heading, and the Customs Tariff Act had to be interpreted independently on its own terms. The record did not support the view that the goods were used only in ignition equipment of internal combustion engines. Heading 85.08 covered ignition and starting equipment, whereas Heading 81.01/04 covered tungsten and articles thereof, which more appropriately described the imported tips.

Conclusion: The goods were not classifiable under Heading 85.08 and were correctly classifiable under Heading 81.01/04 of the Customs Tariff Act, entitling the assessee to consequential relief, including refund if otherwise admissible.

Ratio Decidendi: Where imported goods are merely raw material and not identifiable machine parts, classification must follow the tariff heading that specifically describes the material itself rather than the heading for the end-use equipment.

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