Customs exemption applies where technically identical heating elements satisfy certification requirements despite different trade names.

Mosilit Heating Elements were held entitled to the customs exemption available for Super Kanthal Heating Elements because competent certificates showed both products were technically identical, made of the same chemical composition and used for the same high-temperature furnace application. A mere difference in trade name could not defeat the exemption once the notification's substantive conditions and certification requirements were satisfied. Although exemption notifications must be construed strictly, benefit cannot be denied on a nominal distinction where product identity is established. The denial of exemption solely on the basis of different trade names was therefore unsustainable.

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Issues: Whether Mosilit Heating Elements were entitled to the benefit of the customs exemption notification applicable to Super Kanthal Heating Elements, when the two products were certified to be technically identical and differed only in trade name.

Analysis: The notification granted exemption to the heating elements for the specified use, subject to certification by the designated authorities. The record contained certificates from the competent industrial and electronics authorities stating that Mosilit Heating Elements and Super Kanthal Heating Elements were technically one and the same, being made of the same chemical composition and used for the same high-temperature furnace application. The mere fact that the goods were sold under different trade names could not restrict the scope of the exemption where the substantive product identity and the required certification were established. Though exemption notifications are construed strictly, once the conditions of the notification are satisfied, the benefit cannot be denied on a purely nominal distinction.

Conclusion: The exemption was available to the imported Mosilit Heating Elements, and the denial of benefit on the ground of difference in trade name was unsustainable.

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