Tariff classification of food seasoning mixtures under Heading 3302 turns on essential character, not predominance of odoriferous substances.

Imported food seasoning materials were analysed for tariff classification under Heading 3302 of the Customs Tariff Act. The ingredients and chemical reports showed parsley, spearmint and paprika, bringing the goods within mixtures of odoriferous substances covered by the heading and its HSN notes. Classification had to follow the tariff description, the General Rules for Interpretation, and the essential character test for composite goods. A predominance requirement for the odoriferous substance was rejected because Heading 3302 covers mixtures based on one or more such substances. The goods were therefore classifiable under Heading 3302, and the contrary reclassification was unsustainable.

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Issues: Whether the imported food seasoning materials were classifiable under Heading 3302 of the Customs Tariff Act, 1975 as mixtures of odoriferous substances, or under the rival heading adopted by Revenue.

Analysis: The ingredients and chemical reports showed that the goods contained parsley, spearmint and paprika, which fall within the class of odoriferous substances contemplated by Heading 3302 and the corresponding HSN Notes. The classification exercise had to be undertaken on the basis of the tariff description and the General Rules for Interpretation, particularly the treatment of mixtures and the principle that composite goods are classified according to their essential character. The insistence that odoriferous substances must be the predominant constituent was not supported by the wording of Heading 3302, which covers mixtures based on one or more such substances.

Conclusion: The goods were rightly classifiable under Heading 3302, and the contrary reclassification was unsustainable; the appeal succeeded in favour of the assessee.

Ratio Decidendi: A preparation containing odoriferous substances may fall under Heading 3302 even if mixed with carriers or other ingredients, and classification must follow the tariff heading and essential character test rather than any requirement that the odoriferous substance be the predominant constituent.

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