Manufacture of a distinct excisable product after processing duty-paid seals attracts duty again on the finished article.

Drilling a hole in duty-paid tab seals and inserting a plastic washer was treated as a manufacturing process because it produced a commercially distinct finished article, namely a seal with washer. The resulting commodity was held to be different from the input, so excise duty remained leviable on the finished product even though both the base product and final product fell under the same tariff sub-heading. The document states that manufacture had occurred and that duty was lawfully chargeable again on the processed article.

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Issues: Whether drilling a hole in duty-paid tab seals and inserting a plastic washer resulted in manufacture of a new and distinct excisable product so as to attract duty again.

Analysis: The duty-paid plain seal was subjected to further processing, after which the finished article became a seal with washer. The Tribunal held that the resulting commodity was distinct from the input and that, where manufacture is involved, the resultant product remains dutiable even if the base product and the final product fall under the same tariff sub-heading.

Conclusion: The process amounted to manufacture and duty was lawfully leviable on the finished product again.

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