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Issues: Whether printing on plain plastic films was merely incidental so as to retain classification under Chapter 39, or whether the printing was of a primary nature requiring classification under Chapter 49.
Analysis: The plastic films were printed with details such as the product description, brand particulars, batch number, weight and date of manufacture, enabling the buyer to decide whether to purchase the goods. Such printing was not confined to decorative or incidental matter. Chapter Note 10 to Chapter 39 applies only where printing remains incidental to the primary use of the goods. Where the printing contributes a substantive element to the product's commercial identity and use, the section note assumes precedence and the goods cease to remain classifiable as mere printed plastic sheets under Chapter 39.
Conclusion: The printing was of primary nature and not incidental. Classification was correctly held to fall under Chapter 49, and the appeal by the department failed.
Ratio Decidendi: Where printing on a product is intended to convey commercially significant information that influences the buyer's decision, the printing is not incidental and classification must follow the tariff entry applicable to the printed article rather than the unprinted base material.