Plastic classification turns on finished article status, placing coated HDPE fabric under the residual plastics heading.

HDPE fabric coated with LDPE on both sides was treated as a finished article of plastic rather than a mere sheet, so it fell under Chapter sub-heading 3926.90 for other articles of plastics and not under Chapter sub-heading 3920.38 for plates, sheets, film, foil or strip of plastics. The classification turned on the distinction between plastic sheets and completed plastic articles, with reliance on the view that HDPE woven sacks are articles of plastic. The assessee's classification was upheld and the revenue's challenge failed.

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Issues: Whether the product consisting of HDPE fabric coated with LDPE on both sides was classifiable under Chapter sub-heading 3920.38 as plates, sheets, film, foil or strip of plastics, or under Chapter sub-heading 3926.90 as other articles of plastics.

Analysis: Chapter Heading 3920 covers plates, sheets, film, foil and strip of plastics, while Chapter Heading 3926 covers other articles of plastics and articles of other materials of Heading Nos. 39.01 to 39.14. The decisive question was whether the product was merely a sheet of plastic or a finished article of plastic. Reliance was placed on the earlier High Court view that HDPE woven sacks are articles of plastic, which brought the product within the latter heading rather than the heading for sheets.

Conclusion: The product was correctly classifiable under Chapter sub-heading 3926.90 and not under Chapter sub-heading 3920.38, and the assessee's classification was upheld.

Final Conclusion: The revenue's challenge to the classification failed, and the impugned order in favour of the assessee stood confirmed.

Ratio Decidendi: Where the goods are finished articles of plastic, they fall under the residual heading for other articles of plastics and not under the heading meant for plates, sheets, film, foil or strip of plastics.

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