Tariff classification of cleaning products turns on real nature and use, not the stage of ingredient addition.

Products marketed as "Cleanzo" and "Cleano" were classified by their real nature and use under the Central Excise Tariff. The products were used for cleaning floors, windows and other surfaces, and the addition of pine oil for antiseptic and medicinal purposes did not convert them into soap, because it functioned only as a subsidiary constituent. Applying the HSN notes, soap requires an alkaline salt formed from fatty acids, while cleaning preparations fall under Heading 3402.90. The classification as cleaning preparations was therefore upheld, and the contention for Heading 3401.12 as soap failed.

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Issues: Whether the products "Cleanzo" and "Cleano" were classifiable as soap under Heading 3401.12 or as cleaning preparations under Heading 3402.90 of the Central Excise Tariff.

Analysis: Heading 34.01 covers soap, while Heading 34.02 covers cleaning preparations. The HSN note treats soap as an alkaline salt formed from fatty acids, whereas cleaning preparations generally contain essential constituents and subsidiary constituents such as perfumes and bactericides. The products were used for cleaning floors, windows and other surfaces, and pine oil was added for antiseptic and medicinal purposes, making it a subsidiary constituent rather than a fatty acid used to manufacture soap. The timing of addition of pine oil during blending did not alter its character. The reliance on general references to pine oil in technical literature was not decisive for tariff classification.

Conclusion: The products were correctly classified under Heading 3402.90 as cleaning preparations and not under Heading 3401.12 as soap.

Final Conclusion: The appeals failed on classification, and the impugned classification in favour of the Revenue was sustained.

Ratio Decidendi: For tariff classification, the real nature and use of the product, read with the relevant HSN notes, prevail over the mere stage at which an ingredient is added or its general use in technical literature.

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