Ornamental bird feathers washed, steam-dried and dyed: treated as "prepared" goods, classified under CTI 6701 00 90

The dominant issue was whether ornamental bird feathers that were washed, steam-dried, and dyed were classifiable under CTI 0505 10 90 (raw feathers) or CTI 6701 00 90 (prepared feathers). Applying GRI 1, the authority relied on the terms of the headings, relevant Section/Chapter Notes, and persuasive HSN Explanatory Notes, which state that processing beyond simple cleaning, disinfection, or preservation-expressly including dyeing-removes goods from Heading 0505 and places them under Heading 6701. Given the feathers' working and their intended use as embellishment rather than stuffing material, they were held to be prepared ornamental feathers and classified under CTI 6701 00 90.

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Issues: Whether ornamental bird feathers that have been washed, steam-dried and dyed prior to importation are classifiable under tariff entry 0505 10 90 or under tariff item 6701 00 90 of the First Schedule to the Customs Tariff Act, 1975.

Analysis: Classification is governed by the terms of the relevant headings, Chapter/Section Notes and the General Rules for the Interpretation (GRI) to the First Schedule. Heading 0505 covers feathers that are unworked or merely cleaned, disinfected or treated for preservation. Heading 6701 covers feathers which have undergone processes other than simple cleaning, disinfection or preservation, and expressly includes examples such as dyeing. The HSN Explanatory Notes, which have persuasive value, indicate that dyeing and similar processes remove feathers from heading 0505 and bring them within heading 6701. Applying GRI 1, the textual scope of the headings and the HSN Explanatory Notes show that washed, steam-dried and dyed feathers exceed the permissible processes under heading 0505. There is therefore no need to apply GRI 3(a) because the goods do not prima facie fall under heading 0505 once dyed; heading 6701 specifically covers such processed ornamental feathers.

Conclusion: Ornamental bird feathers that have been washed, steam-dried and dyed prior to importation are classifiable under tariff item 6701 00 90 of the First Schedule to the Customs Tariff Act, 1975, and are not classifiable under heading 0505. This conclusion is in favour of the assessee.

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