Customs exemption classification for polyamides sheets turned on plain reading of the notification and residuary entry scope.

Polyamides plastic sheets were examined for customs exemption classification under the relevant notification. Serial No. 1 was read as covering all goods, including moulding powders of polyamides, and was not confined by implication to primary forms. Serial No. 10 was treated as a residuary entry for Chapter 39 goods not otherwise covered by Serial Nos. 1 to 9. A later amendment widened coverage from specified headings to all Chapter 39 goods, but the imported goods still did not qualify for the lower duty benefit claimed under Serial No. 10 and remained liable under Serial No. 1 at the higher rate.

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Issues: Whether polyamides plastic sheets were classifiable for customs duty benefit under Serial No. 10 of the relevant exemption notification, or whether they fell under Serial No. 1 at the higher rate of duty.

Analysis: The notification was construed on its plain language. Serial No. 1 covered all goods, including moulding powders of polyamides, and could not be restricted by reading into it a limitation to primary forms only. Serial No. 10 was treated as a residuary entry meant only for goods under Chapter 39 not otherwise covered by Serial Nos. 1 to 9. The later amendment enlarged the notification coverage from specified headings to all goods under Chapter 39, but the imported goods did not qualify for the lower rate claimed either before or after that amendment.

Conclusion: The imported goods were not entitled to the lower duty benefit claimed under Serial No. 10 and were liable under Serial No. 1 at the higher rate.

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