Tariff classification of sorbitol mixtures confirmed under Heading 3824; product treated as sorbitol in aqueous solution.

Classification question whether 'Sorbitol Special MDF 85' (a viscous aqueous mixture of sorbitol, mannitol, 1,4-sorbitan and water) falls under CTI 3824 6010 was resolved by applying the General Rules of Interpretation, notably Rule 1 and Rule 3, together with the Explanatory Notes to Heading 3824. The product's composition (sorbitol and sorbitan forming the dominant dry-matter share), its functional characteristics as a plasticizer and anti crystallization agent, and its polyol mixture form satisfy the explanatory criteria for sorbitol syrups, leading to classification under CTI 3824 6010 (sorbitol in aqueous solution).

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Issues: (i) Whether the product "Sorbitol Special MDF 85" (a mixture of sorbitol, mannitol, 1,4-sorbitan and water) is classifiable under CTI 3824 6010 of the First Schedule to the Customs Tariff Act, 1975 or under an alternative/residual entry.

Analysis: The question requires application of the General Rules of Interpretation (GRI) in the First Schedule to the Customs Tariff Act, 1975, including Rule 1 and Rule 3 and relevant Chapter/Heading Explanatory Notes. The product composition on record shows sorbitol and its dehydrated derivative 1,4-sorbitan together constitute approximately 60-70% of the dry matter, with mannitol present as an additional polyol and the product being a viscous aqueous liquid used in pharmaceutical soft-gel applications. Explanatory Note (B)(5) to Heading 3824 covers sorbitol syrups containing other polyols with D-glucitol content normally ranging from 60% to 80% of the dry matter and notes such products are covered by Heading 3824 rather than Heading 2905. GRI 3 requires that where goods are classifiable under two or more headings, the specific heading appropriate to the goods' essential character must be applied rather than a general or residual entry. The product's composition and functional characteristics (plasticizer use, presence of sorbitan preventing crystallization, and mixture of polyols) satisfy the conditions described in the Explanatory Note to Heading 3824.

Conclusion: Issue (i): Classified under CTI 3824 6010 (sorbitol other than that of sub-heading 2905.44: In aqueous solution) of the First Schedule to the Customs Tariff Act, 1975.

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