Synthetic glue classification turned on commercial identity, and the product was treated as glue rather than polyvinyl alcohol.

A synthetic glue made from polyvinyl alcohol, glycerine and water was treated as a prepared adhesive rather than as polyvinyl alcohol. Heading 3905.20 did not apply because it covered the raw material, not the finished adhesive preparation, and Chapter Note 6(a) was inapplicable since the product was not a mere solution of powder in water. Applying common parlance and the heading most akin to the product's commercial identity, the adhesive was classified under Heading 35.01 as glue.

---

---

Issues: Whether the appellant's product, a synthetic glue prepared from polyvinyl alcohol, glycerine and water and used as paper adhesive, was classifiable under Heading 3905.20 as polyvinyl alcohol or under Heading 35.01 as glue.

Analysis: The product had ceased to be mere polyvinyl alcohol and had assumed the character of a prepared adhesive. The classification proposed by the department under Heading 3905.20 was not supported because that heading covered polyvinyl alcohol and not the finished glue preparation. Chapter Note 6(a) did not assist the department since the product was not a simple solution of powder in water but a prepared product containing other ingredients. Since no other heading or chapter specifically covered synthetic glues, the product had to be placed under the heading most akin to it. On the common parlance and use-based approach, glue would include synthetic glue as well.

Conclusion: The product was not classifiable under Heading 3905.20 and was classifiable as glue under Heading 35.01. The classification adopted by the department was rejected and the appeal succeeded.

Final Conclusion: The tariff classification was resolved in favour of treating the product as a glue preparation rather than as polyvinyl alcohol, and the assessee obtained relief.

Ratio Decidendi: Where a manufactured product is known and sold as glue or adhesive, and no specific heading covers the synthetic form, it is to be classified under the heading most akin to its common commercial identity rather than under the heading for the raw material from which it is made.

---