Chemical wood pulp classification: sulphate pulp for further manufacture falls under Chapter 47, not finished sanitary articles.

Imported wood pulp composite core and wood pulp composite for STS were held to fall under Chapter 47 as chemical wood pulp, not Chapter 48 as finished cellulose wadding or sanitary articles. The classification turned on the goods' character as sulphate pulp intended for further manufacture into sanitary napkins, rather than ready-to-use products for household or sanitary use. HSN notes supported treatment of sulphate pulp as raw material under Chapter 47. The imported goods were therefore correctly classifiable under CTH 4703, and the Revenue's challenge failed.

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Issues: Whether the imported goods described as wood pulp composite core and wood pulp composite for STS were classifiable under Chapter 47 as chemical wood pulp or under Chapter 48 as articles of cellulose wadding or webs of cellulose fibres.

Analysis: The classification dispute turned on the nature of the imported goods and the scope of the competing tariff entries. The goods were shown to be sulphate pulp intended for further manufacture into sanitary napkins, and were not in ready-to-use form as sanitary articles. Chapter 47 covers chemical wood pulp, including sulphate pulp, which is used as raw material for absorbent products, whereas Chapter 48 covers finished toilet paper, cellulose wadding and similar sanitary articles. The goods were found to be raw material for further processing and not finished articles directly used for household or sanitary purposes. The HSN notes supported classification of sulphate pulp under Chapter 47 rather than Chapter 48.

Conclusion: The imported goods were correctly classifiable under CTH 4703, and the Revenue's challenge to that classification failed.

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