Classification of impregnated glass fabrics turns on predominance and specificity, with the more specific tariff entry prevailing over the residuary one.

Glass fabrics impregnated with alkyd resin were treated as classifiable under Tariff Item 22F rather than Tariff Item 22B because the material composition of the goods was decisive. Item 22F was regarded as the more specific entry for mineral fibres, yarn and manufactures therefrom, while Item 22B operated as a residuary entry for impregnated textile fabrics not otherwise specified. Prior Tribunal rulings and contemporaneous notifications supported the view that glass fabrics fell within Item 22F. On the test report, the goods substantially consisted of glass fabric coated with synthetic resin, so the predominance test confirmed classification under Item 22F.

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Issues: Whether glass fabrics impregnated with alkyd resin were classifiable under Tariff Item 22B of the Central Excise Tariff or Tariff Item 22F.

Analysis: Tariff Item 22F was treated as the more specific entry for mineral fibres and yarn and the manufactures therefrom, the material composition of the goods being the decisive factor. Item 22B was viewed as a residuary entry for impregnated textile fabrics not elsewhere specified. Prior Tribunal decisions favoured classification under Item 22F, supported by contemporaneous exposition from notifications showing glass fabrics as falling under that entry. On the test report, the goods consisted substantially of glass fabric coated with synthetic resin and the predominance test supported classification under Item 22F.

Conclusion: The goods were held classifiable under Tariff Item 22F and not under Tariff Item 22B.

Ratio Decidendi: Where glass fabric predominates in the goods and Tariff Item 22F specifically covers manufactures of mineral fibres and yarn, that entry prevails over the residuary Item 22B for impregnated glass fabrics.

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