Specific tariff classification of PVC suspension resin prevails over residuary entry, preserving customs exemption entitlement.

Imported PVC suspension resin was treated as classifiable under the specific tariff entry for poly(vinyl chloride) resins rather than the residuary entry, because the more specific description prevails over a general classification under Rule 3(a) of the General Rules for Interpretation. On that basis, the customs exemption attached to the specific entry was available, and denial of the exemption with consequent duty demand could not be sustained. The text also notes that earlier Tribunal and appellate decisions involving identical or substantially similar goods supported this classification approach.

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Issues: Whether the imported PVC suspension resin was classifiable under the specific tariff entry for poly(vinyl chloride) resins or under the residuary entry, and consequently whether the benefit of the customs exemption notification was available.

Analysis: The dispute turned on tariff classification of PVC suspension grade resin. The material had already been examined in earlier Tribunal and appellate decisions involving identical or substantially similar goods, where the specific heading for non-plasticized PVC resins was preferred over the general or residuary entry. Applying Rule 3(a) of the General Rules for the Interpretation of Import Tariff Schedule, the specific description was held to prevail over the more general description. Since the imported goods answered to the specific entry, the denial of exemption and the resultant demand could not be sustained.

Conclusion: The goods were correctly classifiable under the specific tariff entry, and the impugned order denying the exemption and confirming duty was unsustainable.

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