Classification of drum-shaped plywood boxes under the Central Excise Tariff: paper board component held secondary, supporting 4410.90

Drum-shaped boxes made mainly of plywood, with plywood lids and a paper board ring, were treated as classifiable under sub-heading 4410.90 rather than 4819.19 of the Central Excise Tariff Act, 1985. The paper board element was held to be secondary to the plywood structure, so the predominance-of-material argument and the HSN notes for heading 48.19 were rejected. A relied-upon Board circular was also found inapplicable because it concerned composite paper containers for defence ammunition stores.

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Issues: Whether the drum shaped boxes manufactured from plywood and paper board were classifiable under sub-heading 4819.19 or under sub-heading 4410.90 of the Central Excise Tariff Act, 1985.

Analysis: The product was found to be marketed as boxes in drum shape and to be constructed mainly from plywood, with the top and bottom lids made of plywood and the ring made of paper board. The paper board component was held to be secondary to the plywood structure, and the plea based on predominance of material and the HSN notes for heading 48.19 was rejected. The Board circular relied upon was also held to be inapplicable because it related to composite paper containers for defence ammunition stores.

Conclusion: The product was correctly classified under sub-heading 4410.90 of the Central Excise Tariff Act, 1985, and the challenge to that classification failed.

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