Tariff classification of roasted areca nuts confirmed under Heading 2008 19 20 as roasted nuts, not Chapter 8.

Roasted areca nuts in whole, split and cut forms are classifiable under Heading 2008 19 20 as other roasted nuts and seeds, and not under Chapter 8. The roasting process, involving repeated heating and cooling, was treated as distinct from drying, boiling or mere moderate heat treatment, so Chapter Note 3 to Chapter 8 did not cover it. Chapter Note 1(a) to Chapter 20 excluded only goods prepared or preserved by the processes specified in Chapters 7, 8 or 11, while the HSN Explanatory Notes to Heading 2008 expressly include dry-roasted, oil-roasted and fat-roasted areca or betel nuts. The specific tariff entry prevailed over a general entry, and the common parlance test was held inapplicable where the tariff description is specific.

---

---

Issues: Whether roasted areca nuts, in whole, split and cut forms, are classifiable under Heading 2008 19 20 of the Customs Tariff Act, 1975.

Analysis: The goods were found to undergo a roasting process involving repeated heating and cooling, which was treated as distinct from drying, boiling or mere moderate heat treatment. Chapter Note 3 to Chapter 8 was held not to cover roasting, while Chapter Note 1(a) to Chapter 20 excluded only goods prepared or preserved by the processes specified in Chapters 7, 8 or 11. The HSN Explanatory Notes to Heading 2008 specifically include areca or betel nuts that are dry-roasted, oil-roasted or fat-roasted, and the HSN was treated as a safe guide for tariff classification. The Authority also followed the view that a specific entry prevails over a general entry and that the common parlance test has no role where the tariff description is specific.

Conclusion: Roasted areca nuts are classifiable under Heading 2008 19 20 as other roasted nuts and seeds, and not under Chapter 8.

---