Dual-pack epoxy adhesive classification turns on end-use after mixing, not on the separate components' character.

Dual-pack epoxy adhesive resin with hardener was classified by its commercial identity and end-use after mixing, not by the separate characteristics of resin or hardener in isolation. Because the product became an adhesive only when the two components were combined, and an earlier decision involving the same parties had already adopted that approach, the product was held classifiable under Tariff Item 68 rather than Tariff Item 15A(I). The Revenue's appeal was rejected on that basis.

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Issues: Classification of dual pack epoxy adhesive resin with hardener, namely whether it fell under Tariff Item 15A(I) or Tariff Item 68 of the Central Excise Tariff.

Analysis: The product was sold as a dual pack in separate containers and became an adhesive only when mixed. The separation preserved the resin and hardener until use, and the decisive consideration was the character and end-use of the combined product. The earlier decision in the same parties' case had already held that such dual packs were classifiable as an adhesive under Tariff Item 68, and the same reasoning was followed.

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

Ratio Decidendi: Where a dual-pack product acquires its commercial identity and use only on mixing, classification turns on its end-use as the resulting adhesive rather than on the separate components or the principal characteristics of one component.

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