Tariff classification of adhesive tapes turns on whether the goods are rubberized textile fabrics or merely coated textile fabrics.

Classification turned on whether the adhesive tapes and related products, made from fabric processed into final goods and coated with adhesive after treatment in rubberized solution, fell within heading 5906 as rubberized textile fabrics or heading 5907 as textile fabrics otherwise impregnated, coated or covered. The note records that the lower authority's finding that the goods were rubberized fabrics was not disputed, and that heading 5906 was treated as the more specific entry for such goods. The precedent relied on at appellate stage was distinguished because it concerned goods not found to be rubberized fabrics.

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Issues: Whether the assessee's adhesive tapes and related products were classifiable under heading 5906 as rubberized textile fabrics, or under heading 5907 as textile fabrics otherwise impregnated, coated or covered.

Analysis: The products were found to be fabrics processed into final goods and, on the admitted manufacturing process, were coated with adhesive after being framed in rubberized solution and thereafter cut, slit and shaped as labels. The finding of the lower authority that the goods were rubberized fabrics was not disputed by the Revenue. Heading 5906 specifically covered rubberized textile fabrics, whereas heading 5907 applied to textile fabrics otherwise impregnated, coated or covered. The earlier precedent relied on by the appellate authority was distinguished because it dealt with goods found not to be rubberized fabrics.

Conclusion: The goods were correctly classifiable under heading 5906 and not under heading 5907; the assessee succeeded.

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