Classification of printed cartons turns on the finished material used, not the parent raw material classification.

For classification of printed corrugated cartons and boxes, the decisive factor is the material from which the finished goods are directly made, not the classification of the parent raw material used to create the intermediate corrugated board. Where duplex board is first corrugated and then used to produce printed cartons, the finished cartons answer the description of printed cartons made wholly out of paper or paperboard and fall under Heading 4818.12. On that basis, exemption under Notification No. 140/86-CX cannot be denied merely because the parent material had a different classification, and the Revenue's contrary view was rejected.

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Issues: Whether printed corrugated cartons/boxes manufactured out of corrugated paper and paperboard were classifiable under Heading 4818.12 and entitled to exemption under Notification No. 140/86-CX, or whether classification had to be determined with reference to the base material used to make the intermediate corrugated board.

Analysis: The relevant test was whether the finished printed cartons were made wholly out of paper or paperboard. The material from which the finished goods were directly made was held to be decisive, and not the original raw material or parent material from which the intermediate corrugated board emerged. Once duplex board was corrugated, it fell under the corrugated board entry, and printed cartons made from such corrugated board answered the description of printed cartons made wholly out of paper or paperboard covered by the tariff entry. On that basis, the exemption could not be denied merely because the parent material had a different classification.

Conclusion: The cartons were classifiable under Heading 4818.12 and were eligible for the exemption under Notification No. 140/86-CX; the Revenue's contrary classification was rejected.

Final Conclusion: The appeal was dismissed and the order granting the assessee the benefit of the exemption and the corresponding classification was upheld.

Ratio Decidendi: For classification of printed cartons/boxes, the decisive factor is the material from which the finished goods are directly made, not the classification of the parent raw material used to create the intermediate board.

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