Processed cellulose powder classified as a high polymer under the customs tariff, not under the residuary entry.

Imported cellulose powder, though processed and not in its natural form, was treated as a natural carbohydrate high polymer on the basis of technical literature and CCCN classification opinions. Because the product retained the character of cellulose as a high polymer, it fell within Heading 39.01/06 of the Customs Tariff Schedule and Item 15A(1) of the Central Excise Tariff Schedule for additional duty purposes, rather than Item 68. The intended use of the goods and the absence of persuasive proof about a local product's classification under Item 68 did not alter the tariff classification.

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Issues: Whether imported cellulose powder was classifiable for the purpose of additional duty of customs under Heading No. 39.01/06 of the Customs Tariff Schedule and Item No. 15A(1) of the Central Excise Tariff Schedule, or under Item No. 68 of the Central Excise Tariff Schedule.

Analysis: The imported goods were described as highly purified cellulose powder and were not in their natural form. The relevant tariff entry covered, apart from artificial or synthetic resins and plastic materials, other high polymers. Relying on technical literature, the Court held that cellulose is a natural carbohydrate high polymer and that the material imported, being a processed cellulose product, retained that character. The fact that the goods were used for a different purpose and the absence of persuasive proof regarding the classification of a local product under Item 68 did not alter the tariff position. The goods also found support in the classification opinions cited from the CCCN.

Conclusion: The imported cellulose powder was correctly classifiable under Heading No. 39.01/06 of the Customs Tariff Schedule and Item No. 15A(1) of the Central Excise Tariff Schedule, and not under Item No. 68.

Ratio Decidendi: A processed cellulose product that is a high polymer falls within the tariff entries covering other high polymers for the purpose of additional duty of customs.

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