Tariff classification of coated rexine cloth turns on statutory definition, with base-fabric predominance controlling the entry.

Tariff Item 19(III) covers cotton fabrics impregnated, coated or laminated with artificial plastic materials, and the predominance or percentage conditions are to be tested against the base fabric, not the finished coated product. The statutory definition prevails over any contrary common parlance or trade understanding. On that construction, coated rexine cloth on a cotton base falls within the tariff entry because the coating is predominantly plastic in character, so the product is classifiable under Tariff Item 19(III) and duty is payable accordingly.

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Issues: Whether coated rexine cloth manufactured on a cotton base falls within Tariff Item 19(III) as cotton fabrics impregnated, coated or laminated with artificial plastic materials, and whether the predominance or percentage requirements in the tariff item are to be applied to the finished coated product or to the base fabric.

Analysis: Tariff Item 19 expressly includes fabrics impregnated, coated or laminated with preparations of cellulose derivatives or other artificial plastic materials. The proviso and Explanation I make it clear that, for such goods, the predominance or percentage conditions are to be tested with reference to the base fabric, not the finished coated fabric. The item was designed to bring these coated fabrics within the definition of cotton fabrics notwithstanding any common parlance distinction, and the statutory definition controls over trade understanding. The coating material used in the product was also found to be predominantly plastic in character, so the product answered the description in the tariff entry.

Conclusion: The coated rexine cloth was correctly classifiable under Tariff Item 19(III) and duty was payable accordingly; the Revenue succeeded.

Ratio Decidendi: Where a tariff entry expressly includes coated or laminated fabrics and specifies that predominance or percentage conditions apply to the base fabric, the statutory definition governs classification and excludes a contrary common parlance approach.

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