Tariff classification of fusible interlining fabrics turns on coating characteristics and Chapter 59 criteria, placing the product under Heading 5903.

Fusible interlining fabric of cotton was analysed under the tariff rules for impregnated, coated, covered or laminated textile fabrics, with Chapter Note 2(a) to Chapter 59 and the HSN explanatory notes treated as substantially consistent classification criteria. Applying the test report, the fabric was found coated on one side, capable of being bent without fracturing, and not completely embedded in plastics. On that basis, and with the cited precedents and circulars supporting the same approach, the product was held classifiable under Heading 5903 of Chapter 59 and not under Chapter 52.

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Issues: Whether the product "fusible interlining fabrics of cotton" is correctly classifiable under Heading 5903 of Chapter 59 of the Customs Tariff Act, 1975, or under Chapter 52.

Analysis: The authority examined the general rules for interpretation, Chapter Note 2(a) of Chapter 59, the HSN explanatory notes, the notification applying the Customs Tariff headings to GST classification, and the ATIRA test report. It found that the Chapter 59 note and the HSN explanatory note conveyed substantially the same classification criteria, and that the sample satisfied the conditions for Heading 5903. On the test findings, the fabric was coated on one side, could be bent without fracturing, was not completely embedded in plastics, and was not shown to fall within the excluded categories relied upon by the appellant. The authority also held that Chapter 52 headings did not cover laminated fabrics or fabrics coated with plastics, and that the cited precedents and circulars supported classification under Heading 5903.

Conclusion: The product is classifiable under Heading 5903 of Chapter 59 and not under Chapter 52.

Ratio Decidendi: For tariff classification of impregnated, coated, covered or laminated textile fabrics, the governing tariff note and the tested characteristics of the goods determine classification, and a fabric satisfying the criteria for Heading 5903 remains classifiable thereunder.

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