Button cells treated as dry electric batteries where their electrical function brings them within the tariff battery entry.

Button cells were held classifiable as dry electric batteries under Item 31(i) of the Central Excise Tariff, not as residuary goods under Item 68, because the decisive test is their function. The classification turned on whether the cells generate and transmit electrical energy to operate a device, not on their shape, raw material, manufacturing technology, or specific end use. As button cells, like other dry cells, cause current to flow between electrodes and are used to power watches, they fall within the battery entry, and the classification was in favour of the Revenue.

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Issues: Whether button cells are classifiable as dry electric batteries under Item 31(i) of the Central Excise Tariff or as goods under the residuary Item 68.

Analysis: Item 31(i) covers dry electric batteries and parts thereof. The decisive factor is not the shape, raw material, or manufacturing technology of the cell, but whether it functions as a battery by generating and transmitting electrical energy to operate the device. Button cells, like other dry cells, cause current to flow between electrodes when the circuit is closed and are used to drive watches. Their different technology or end use does not take them outside the battery entry.

Conclusion: The button cells are classifiable under Item 31(i) of the Central Excise Tariff and not under Item 68. The classification is in favour of the Revenue.

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