Tariff classification of printed labels turns on their material and use, not merely the presence of printed matter.

Printed labels are not automatically products of the printing industry for tariff purposes where the printing is incidental and the article functions as an attachment to other goods. Printed plastic labels were classified under Heading 39.19 rather than Chapter 49; printed cloth labels were excluded from Heading 59.05 and classified under Heading 59.06; and printed aluminium labels were taken outside Chapter 49 and classified under Heading 76.06 before 1-3-1988 and under Sub-heading 7607.50 thereafter. The classification of paper labels was left undisturbed under the accepted paper headings.

---

---

Issues: (i) Whether printed plastic labels are classifiable as products of the printing industry under Chapter 49 or under Chapter 39; (ii) whether printed cloth labels fall under Heading 59.05 or Heading 59.06; and (iii) whether printed aluminium labels are classifiable under Heading 49.01 or under Chapter 76, and if so, under which headings for the relevant periods.

Issue (i): Whether printed plastic labels are classifiable as products of the printing industry under Chapter 49 or under Chapter 39.

Analysis: The labels were held not to be products of the printing industry merely because they bore printed matter. The deciding consideration was that the labels functioned as adjuncts to the goods on which they were affixed, and the printing was incidental to their use. The Court relied on the tariff scheme and the distinction between printed material that is itself bought for its printed content and labels whose utility lies in their role as attachments to other goods. Decalcomanias were found to be different from such labels.

Conclusion: Printed plastic labels are not classifiable under Chapter 49 and are classifiable under Heading 39.19.

Issue (ii): Whether printed cloth labels fall under Heading 59.05 or Heading 59.06.

Analysis: Since labels were not accepted as products of the printing industry, classification under Chapter 49 was rejected. Heading 59.05 was found inappropriate because it covers rubberised fabrics, whereas the goods in question were not rubberised fabrics. The proper residual textile heading applicable to the coated or otherwise treated textile material was therefore identified.

Conclusion: Printed cloth labels are not classifiable under Heading 59.05 and are classifiable under Heading 59.06.

Issue (iii): Whether printed aluminium labels are classifiable under Heading 49.01 or under Chapter 76, and if so, under which headings for the relevant periods.

Analysis: The Court held that aluminium labels were also not products of the printing industry. On the tariff description, printed aluminium foil fell within the aluminium headings of Chapter 76 for the relevant periods, with the specific heading changing according to the thickness criterion and the tariff amendment effective from 1-3-1988.

Conclusion: Printed aluminium labels are not classifiable under Chapter 49 and are classifiable under Heading 76.06 prior to 1-3-1988 and under Sub-heading 7607.50 thereafter.

Final Conclusion: The classification dispute was resolved issue-wise, with printed plastic and aluminium labels placed outside Chapter 49, printed cloth labels shifted to the appropriate textile heading, and printed paper labels left undisturbed under the accepted paper headings.

Ratio Decidendi: For tariff classification, printed labels are not automatically products of the printing industry; where the printing is merely incidental and the article functions as an adjunct or attachment to another product, classification depends on the material and tariff description applicable to the article itself.

---