Wool grease classified as animal fat under Heading 15.01, not as residue under Heading 15.07.

Wool grease was classified as an animal fat under Heading 15.01 because it is obtained from wool scouring liquor and is described in the HSN Explanatory Notes as a sticky fat. The fact that it is not chemically a glycerol ester did not move it to Heading 15.07, which covers vegetable waxes, beeswax, other insect waxes, spermaceti, degras and residues and does not describe wool grease. Note 2 to Chapter 15 referred only to wool grease residues and did not control classification of wool grease itself. The assessee's classification was upheld and the appeals succeeded.

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Issues: Whether wool grease is classifiable under Heading 15.01 as animal fat or under Heading 15.07 as degras or residue.

Analysis: Heading 15.01 covers animal fats and oils, crude, refined or purified. Wool grease is obtained from the soapy water used in scouring wool and, according to the HSN Explanatory Notes, is a sticky fat. The reasoning that it is not chemically a glycerol ester was not sufficient to place it in Heading 15.07, because that heading covers vegetable waxes, beeswax, other insect waxes, spermaceti, degras and residues, which do not describe wool grease. Note 2 to Chapter 15 referred to wool grease residues and did not control the classification of wool grease itself. The classification adopted earlier for lanolin as an animal fat also supported the view that wool grease is the crude form of the same product.

Conclusion: Wool grease is classifiable under Heading 15.01 and not under Heading 15.07.

Final Conclusion: The classification adopted by the assessee was upheld and the appeals succeeded.

Ratio Decidendi: A product described in the tariff and explanatory notes as a sticky animal fat is to be classified under the heading covering animal fats and oils, and not under a heading meant for vegetable waxes, degras or residues.

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