Essential character does not control countervailing duty where imported bulb parts lack integral components and remain parts.

Imported pre-focused bulb parts cleared without caps and collars were not assessable as complete bulbs for countervailing duty. Although customs classification may treat an incomplete article as the finished article where it has the essential character of that article, the additional duty regime required assessment under the Central Excise Tariff on the goods' actual condition unless a corresponding deeming provision applied. Because the missing caps and collars were integral to the complete bulb in trade and ordinary use, the goods retained the character of parts, even though they could glow when connected to power. The articles were therefore classifiable as parts under the residual tariff item.

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Issues: Whether imported pre-focused bulb parts, cleared without caps and collars, were to be treated as complete bulbs for countervailing duty purposes or as parts assessable under the residual tariff item.

Analysis: The basic customs classification treated the goods with the aid of interpretative rules and the relevant section note as falling under the heading applicable to the complete article, because for customs duty an incomplete article having the essential character of the finished article may be classified accordingly. For countervailing duty, however, the applicable test was the Central Excise Tariff read with the additional duty scheme, and in the absence of a corresponding deeming provision the imported goods had to be assessed according to their actual condition. As the goods were admittedly imported without caps and collars, and those components were part of the complete bulb in trade and ordinary use, the imported articles retained the character of bulb parts and could not be treated as complete bulbs merely because they could glow when connected to a power source.

Conclusion: The imported goods were assessable as parts and not as complete bulbs for countervailing duty purposes, and the assessee succeeded.

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