Mineral fibre classification prevails when commercial identity and essential character show glass fibre goods are not textile fabrics.

Glass fabrics (epoxy B stage) and varnished or unvarnished fibre glass sleeves, including scrap, were treated as manufactures of glass fibre, a mineral fibre, rather than as textile fabrics. Classification depended on the essential character and commercial identity of the goods, not merely on impregnation, coating or laminating. Because the mineral fibre element predominated and the goods were not known in trade as textile fabrics, the specific entry for mineral fibres and manufactures therefrom prevailed over the textile fabric entry. On that basis, the departmental view on Tariff Item 22B was rejected and the exemption under the relevant notification remained available.

---

---

Issues: Whether glass fabrics (epoxy B stage) and varnished and unvarnished fibre glass sleeves with their scrap were classifiable under Tariff Item 22F or Tariff Item 22B, and whether they continued to enjoy exemption under the relevant notification.

Analysis: The goods were manufactured from glass fibre, which is a mineral fibre. The decisive factor was not the process of impregnating, coating or laminating, but the true nature of the manufacture and whether mineral fibres or yarn predominated in the product. The residuary treatment under the item for textile fabrics could not displace the specific entry dealing with mineral fibres and manufactures therefrom. The Court also applied the ordinary commercial understanding of the goods and found that in trade they were not known as textile fabrics. On that basis, the departmental classification under Tariff Item 22B was held to be unsustainable.

Conclusion: The goods were held to fall under Tariff Item 22F and not Tariff Item 22B, and the exemption under the notification remained available.

Ratio Decidendi: Where a tariff entry specifically covers mineral fibres and manufactures therefrom, the classification must be determined by the essential character and commercial identity of the goods, and a superadded process such as impregnation, coating, or laminating does not take the goods out of that specific entry if mineral fibre predominates.

---