Manufacture test for processed fabric rejected where washing and packing did not create a new excisable product.

Cutting, washing, drying, folding and packing acrylic knitted fabric into sanitary napkin covers did not amount to manufacture because the process did not change the essential character of the goods or bring into existence a new product. The article continued to retain its absorbency and remained usable as a sanitary napkin cover after processing. Mere addition of a brand name or packing in a printed bag was insufficient to create a distinct excisable product. On that basis, the duty demand based on such classification could not be sustained.

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Issues: Whether washing, drying, folding and packing acrylic knitted fabric cut to size as sanitary napkin covers amounted to manufacture, and if not, whether any duty liability could arise on that process.

Analysis: The process did not bring about any change in the essential character of the goods. Washing and packing were not treated as manufacturing processes under the relevant chapter note, and no new product came into existence because the article retained its absorbency and remained usable as a sanitary napkin cover even after the processing. The mere addition of a brand name or packing in a printed bag did not convert the original fabric into a distinct excisable product.

Conclusion: The process did not amount to manufacture and the demand based on such classification could not be sustained.

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