Specific tariff heading prevails for insulating fittings used in electrical equipment, displacing classification as general parts.

Contact plates and double bushings imported for electrical equipment retained their character as insulating fittings, even though they were component parts of electrical machinery. Applying Note 2(a) to Section XVI and the principle that a specific tariff description prevails over a broader heading for parts, the Tribunal found that Heading 85.18/27(1) for insulating fittings was the correct classification. The competing claim under Heading 85.18/27(3) for parts of electrical apparatus was rejected because that sub-item did not cover insulating fittings. The customs classification under the specific heading was upheld and the appeals were dismissed.

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Issues: (i) Whether contact plates and double bushings imported for electrical equipment were insulating fittings for electrical items; (ii) whether the goods were classifiable under Heading 85.18/27(3) as parts of electrical apparatus or under Heading 85.18/27(1) as insulating fittings.

Issue (i): Whether contact plates and double bushings imported for electrical equipment were insulating fittings for electrical items.

Analysis: The imported articles were accepted to be component parts of electrical machinery, but that did not exclude their distinct identity as insulating fittings. Note 2(a) to Section XVI required goods described in a specific heading of Chapters 84 and 85 to be classified in that heading. On the facts, the articles retained the character of insulating fittings for electrical equipment.

Conclusion: The articles were insulating fittings for electrical items.

Issue (ii): Whether the goods were classifiable under Heading 85.18/27(3) as parts of electrical apparatus or under Heading 85.18/27(1) as insulating fittings.

Analysis: Heading 85.18/27 specifically covered insulating fittings for electrical equipment, and the presence of a more specific description displaced classification under the claimed sub-item for parts. The Tribunal applied the principle that a specific tariff heading for the goods themselves takes precedence over a heading for the machine or apparatus of which they form part. Since sub-items (2) and (3) did not cover insulating fittings, classification under sub-item (1) was appropriate.

Conclusion: The goods were correctly classifiable under Heading 85.18/27(1), not under Heading 85.18/27(3).

Final Conclusion: The classification adopted by the customs authorities was upheld, and the appeals were dismissed.

Ratio Decidendi: Where goods are specifically described in a tariff heading as insulating fittings, they must be classified under that specific heading and not under a broader heading for parts of the apparatus of which they form part.

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