Synthetic resin classification prevails where a condensation product is cleared as resin and becomes glue only after further mixing.

Prescol Glue grades G, L, PW and TUL was classified as a synthetic resin under Tariff Item 15A(1) because it was manufactured by a condensation process and fell within the entry covering aminoplasts and condensation products, including products that were modified or polymerised. The classification turned on the condition in which the product was cleared from the factory: it was removed in powder form as a resin and became glue only after later mixing with other ingredients. Its water solubility and low molecular weight did not exclude it from Item 15A(1). Tariff Item 68, being residuary, could apply only if the specific entry was inapplicable, which was not the case.

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Issues: Whether Prescol Glue, grades G, L, PW and TUL, was classifiable as a synthetic resin under Tariff Item 15A(1) of the erstwhile Central Excise Tariff or as glue/adhesive under Tariff Item 68.

Analysis: The product was manufactured by a condensation process and answered the description of aminoplasts and condensation products expressly included in Tariff Item 15A(1). The Tariff entry covered condensation products whether or not modified or polymerised and did not require a particular molecular weight or completion of condensation to the final stage. The fact that the product was water soluble, of low molecular weight, or later used as an adhesive did not remove it from Item 15A(1), because classification depended on the condition in which it was cleared from the factory. The product was cleared in powder form as a synthetic resin and became glue only after further mixing with other ingredients. Tariff Item 68, being a residuary entry, could apply only if classification under the specific tariff item was ruled out.

Conclusion: The product was classifiable under Tariff Item 15A(1) as a synthetic resin and not under Tariff Item 68; the Revenue's appeal succeeded.

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