Classification of coil-form heating goods without ceramic support as heat resistors under Chapter Heading 85.16

Goods described as heating elements, when cleared in coil form without ceramic support, were treated as heat resistors rather than complete heating elements. Technical literature noted that ceramic support was required for a heating element, and in its absence the goods retained the character of heat resistors. Chapter Heading 85.16 specifically covered heat resistors, and the HSN Explanatory Notes supported classification under that heading. The goods were therefore classified under Chapter Heading 85.16 instead of Chapter Heading 85.14.

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Issues: Whether the goods described as heating elements, cleared in coil form without ceramic support, were classifiable under Chapter Heading 85.14 or Chapter Heading 85.16.

Analysis: The goods were cleared as coils without ceramic support. On the technical literature relied upon, a heating element requires ceramic support, and without such support the goods remained in the form of heat resistors. Chapter Heading 85.16 specifically covered heat resistors, and the HSN Explanatory Notes also indicated classification under that heading.

Conclusion: The goods were correctly classifiable under Chapter Heading 85.16, and the appeal was not sustainable.

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