Composite product classification turns on end use and commercial identity, not mere predominance of one constituent.

Repacked duty-paid resin and hardener in dual containers retained their character until mixed, and repacking alone did not create a new excisable product. Classification turned on the character and commercial identity of the final marketed article, including its intended use as an adhesive after mixing. Because resin was only one constituent of the composite product, it could not be classified under Tariff Item 15A(1 merely on predominance; the proper classification was under Tariff Item 68. The Revenue's challenge therefore failed.

---

---

Issues: Whether the product repacked in dual containers, consisting of resin and hardener, was correctly classifiable under Tariff Item 15A(1) or under Tariff Item 68.

Analysis: The product was repacked into separate containers and retained its character as resin and hardener until mixed. The reasoning accepted that repacking of duty-paid goods, by itself, does not necessarily create a new excisable product. The decisive consideration was the character and use of the final marketed article. Since the contents were intended to be mixed and used together as an adhesive, the relevant criterion for classification was the end use of the composite product rather than the individual predominance of resin or hardener. On that basis, the article did not fit classification under Tariff Item 15A(1) merely because resin formed the principal component.

Conclusion: The product was classifiable under Tariff Item 68 and not under Tariff Item 15A(1); the Revenue's appeal therefore failed.

Ratio Decidendi: For classification, the end use and commercial identity of the final composite product are material, and duty-paid resin cannot be reclassified under Tariff Item 15A(1) merely because it is repacked or because one constituent is predominant.

---