Relabelling of chemical containers was not manufacture, so duty, interest and penalties could not survive.

Removal of original labels from chemical containers and affixation of new labels was treated as mere relabelling, not packing or repacking from bulk to retail packs. On the facts found, this limited activity did not amount to manufacture under the relevant chapter note for either the pre-1997 or post-1997 period, as the later amendment did not change the legal position. Because the process did not involve further processing making the goods marketable in the manner required for manufacture, the duty demand, interest and penalties could not be sustained.

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Issues: Whether removal of original labels from chemical containers and affixation of new labels amounted to manufacture under the relevant chapter note for the periods before and after 1997.

Analysis: The activity was only relabeling of chemicals in drums and carboys, without any packing or repacking from bulk to retail packs. The applicable chapter note, as interpreted in the cited decisions, did not treat such limited relabeling as manufacture for the earlier period, and the later amendment did not alter the result on the facts found. The activity did not bring about any further processing that would make the goods marketable in the sense required for manufacture.

Conclusion: The activity did not amount to manufacture for either period, and the demand of duty, interest, and penalties could not survive.

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