Electroplating of wires and strips is not manufacture where no new commodity emerges under the essential character test.

Electroplating and galvanising of wires and strips were considered as metal-deposition processes, but the controlling test remained whether the operation alters the form, structure or essential character of the commodity and produces a new and different article. The tariff heading by itself was not decisive on manufacture. Applying the principle that galvanising does not create a distinct commodity, the same reasoning was applied to electroplating, with the result that electroplating of wires and strips was held not to amount to manufacture or bring into existence a new commodity.

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Issues: Whether galvanising or electroplating of wires and strips amounts to manufacture so as to bring into existence a new and different commodity.

Analysis: Galvanising and electroplating are different processes, but both result in the deposition of metal on the article. The controlling test is whether the process alters the form, structure, or essential character of the commodity and results in a new commodity; the tariff heading itself does not decide the issue of manufacture. Applying the principle that galvanising does not bring about emergence of a distinct commodity, the same reasoning applies to electroplating.

Conclusion: Electroplating of wires and strips does not amount to manufacture and does not give rise to a new commodity; the appeal fails.

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