Betel nut classification turns on whether processing creates a true preparation, not mere cleaning or flavouring.

API supari, chikni supari, unflavoured supari, flavoured supari and boiled supari were treated as betel nuts retaining their Chapter 8 character because the processes applied to them were limited to cleaning, preservation, polishing, boiling and improvement of appearance. The addition of flavouring agents did not, by itself, convert flavoured supari into a preparation of betel nut. Supplementary Note 2 to Chapter 21 was held insufficient to override classification where the goods had not acquired the tariff character of a true preparation. The five goods were therefore classifiable under heading 0802, not under sub-heading 21069030.

---

---

Issues: Whether API supari, chikni supari, unflavoured supari, flavoured supari and boiled supari are classifiable under heading 0802 of the Customs Tariff Act, 1975 or as betel nut product known as supari under sub-heading 21069030.

Analysis: The goods were found to be based on raw betel nuts, and the processes applied to API, chikni, unflavoured and boiled supari were held to be processes of cleaning, preservation and improvement of appearance within Chapter Note 3 to Chapter 8, so that the betel nuts retained their character as betel nuts. For flavoured supari, the addition of flavouring agents was held not to change the essential character of the goods into a preparation of betel nut. The ruling also treated Supplementary Note 2 to Chapter 21 as insufficient, by itself, to displace the classification of goods that had not become preparations in the tariff sense.

Conclusion: The five goods are not preparations of betel nut classifiable under sub-heading 21069030 and are classifiable under Chapter 8, more precisely heading 0802 of the Customs Tariff Act, 1975.

Ratio Decidendi: Processes such as cleaning, preservation, polishing, boiling, roasting and addition of flavouring agents do not shift betel nut from Chapter 8 to Chapter 21 unless the goods acquire the character of a true preparation of betel nut.

---