Specific tariff entry prevails over residuary classification for electric heating resistors, regardless of intended industrial use.

Electric heating resistors were held classifiable under the specific tariff entry for electric heating resistors, because a specific description prevails over a residuary heading. Their intended industrial use did not shift classification to the heading for industrial furnaces or ovens, since tariff nomenclature controlled the result. The goods were therefore correctly classified under Heading 8516 and not under Heading 8548 or Heading 8514, and the lower authorities' classification was upheld.

---

---

Issues: Classification of electric heating resistors whether under Heading 8516 as the specific entry or under Heading 8548 as the residuary entry, and whether their intended industrial use could shift them to Heading 8514.

Analysis: Heading 8516 specifically covers electric heating resistors other than those of Heading 8545. Heading 8548 is residuary in nature and cannot be preferred over a specific tariff entry. Although industrial furnaces and ovens may fall under Heading 8514, the presence of a specific entry for electric heating resistors required the goods to be classified by that specific description, regardless of their intended industrial use.

Conclusion: The goods were correctly classified under Heading 8516 and not under Heading 8548 or Heading 8514. The classification adopted by the lower authorities was upheld.

Ratio Decidendi: Where goods are covered by a specific tariff description, that specific entry prevails over a residuary heading, and end use will not displace the classification fixed by the tariff nomenclature.

---