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Issues: Whether blankets manufactured from shoddy yarn, in which wool predominates by weight, are classifiable as blankets of wool and entitled to exemption under Serial No. 152(a) of Notification No. 4/97 dated 1-3-1997.
Analysis: The tariff did not define blankets of wool, so classification had to be determined by the textile composition rule in Note 2(A) of Section XI, read with the corresponding sub-heading notes. Those provisions require a product of Chapters 56 to 63 containing two or more textile materials to be treated as consisting wholly of the textile material that predominates by weight. As wool was not disputed to predominate, blankets made from shoddy yarn were to be treated as blankets of wool. The absence of any express exclusion for regenerated or garneted wool also supported this view. The exemption scheme showed a consistent legislative intention to exempt blankets made from shoddy yarn, with the later notifications only introducing a value ceiling.
Conclusion: Blankets manufactured from shoddy yarn with wool predominating are eligible for exemption under Serial No. 152(a) of Notification No. 4/97, and the demand, interest, and penalties could not stand.