Manufacture test for slitting jumbo rolls referred to Larger Bench amid conflicting precedent on new product identity.

Slitting and cutting duty-paid jumbo rolls into smaller rolls was examined on whether the process amounts to manufacture under section 2(f), in light of conflicting authority on whether a new commercially known product emerges. The order noted that the issue has implications for duty liability, penalty, and credit, and that the applicability of precedent to the facts required authoritative resolution. The question of manufacture was therefore referred to a Larger Bench for decision.

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Issues: Whether the activity of slitting and cutting duty-paid jumbo rolls into smaller rolls amounted to manufacture, and whether the question required reference to a Larger Bench for resolution.

Analysis: The order noticed competing lines of authority on whether slitting of jumbo rolls results in a new commercially known product and whether the process answers the statutory concept of manufacture under section 2(f). It also noted that the issue had implications for duty liability, penalty, and credit, and that the applicability of precedent to the facts required authoritative determination.

Outcome: The question of manufacture was referred to a Larger Bench for decision.

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