Classification of natural high polymers under tariff heading 15A(1) extends beyond synthetic materials where the wording is unrestricted.

Tariff Heading 15A(1) covers "other high polymers" without limiting that expression to artificial or synthetic materials, so a natural high polymer may also fall within the heading unless the tariff language excludes it. On that construction, imported Gutta Percha Raw 08, being accepted as a high polymer, was classifiable under Tariff Heading 15A(1) for countervailing duty rather than under Tariff Item 68. The earlier silicone emulsion ruling was distinguished because it concerned a different tariff phrase and different factual context.

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Issues: Whether imported Gutta Percha Raw 08, being a natural high polymer, was classifiable for countervailing duty under Tariff Heading 15A(1) of the Central Excise Tariff or under Tariff Item 68 of the Central Excise Tariff.

Analysis: The goods were accepted to be a high polymer. Tariff Heading 15A(1) uses the expression "other high polymers" without qualifying it by the words artificial or synthetic, and the heading also includes certain natural products by specific name. On that basis, the expression could not be confined only to artificial or synthetic high polymers. The reliance placed on the earlier decision concerning silicone emulsion did not assist the respondent because that case turned on different facts and the dispute there was about the scope of "other materials" rather than a product answering the description of high polymer itself.

Conclusion: The imported goods were correctly classifiable under Tariff Heading 15A(1), and the contrary view placing them under Tariff Item 68 was erroneous. The appeal was therefore allowed in favour of Revenue.

Ratio Decidendi: Where a tariff entry refers to "other high polymers" without restricting the expression to artificial or synthetic varieties, the entry covers both natural and artificial high polymers unless the tariff language itself excludes them.

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