Relabelling imported medicaments without repacking is not manufacture under Chapter 30's extended definition.

Relabelling imported patent and proprietary medicaments did not amount to manufacture under Chapter Note 5 of Chapter 30 where the goods were already packed in retail cartons on import and only stickers were pasted on vials or bottles after removal from master boxes. Chapter Note 5 extends manufacture to specified acts, including relabelling of containers intended for consumers and repacking from bulk to retail packs, but the activity here did not involve repacking and was confined to relabelling alone. Applying the governing principle that relabelling by itself is insufficient, the activity was held not to be manufacture and the Revenue's appeal was dismissed.

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Issues: Whether relabelling of imported patent and proprietary medicaments, without repacking from bulk packs to retail packs, amounts to manufacture under Chapter Note 5 of Chapter 30.

Analysis: Chapter Note 5 treats as manufacture, in relation to products of heading 30.03, conversion of powder into tablets or capsules, labelling or relabelling of containers intended for consumers, repacking from bulk packs to retail packs, or any other treatment rendering the product marketable. The activity in question was confined to taking out already packed retail cartons from the master box and pasting stickers on the vials or bottles. The retail packs were already intact on import, and there was no repacking from bulk packs to retail packs. On the earlier remand and in light of the governing principle that relabelling alone is not enough, the activity did not satisfy the extended meaning of manufacture.

Conclusion: The activity did not amount to manufacture, and the Revenue's appeal was dismissed.

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