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Issues: Whether the product, a cellulosic sponge used for wiping and cleaning household surfaces, was classifiable as a mop under Heading 96.03 of the Central Excise Tariff or under the residuary sub-heading 3926.90.
Analysis: The product was a sponge piece without a handle. The HSN Explanatory Notes to Heading 96.03 describe a mop as a bundle of textile cords or vegetable fibres mounted on a handle, and dictionary meanings similarly require an absorbent material fastened to a long handle or stick. On that basis, the product was not of the same kind or nature as goods covered by Heading 96.03. Rule 3 of the Rules for the Interpretation of the Schedule to the Central Excise Tariff was held to be inapplicable because the goods were found classifiable under only one heading.
Conclusion: The product was not classifiable as a mop under Heading 96.03 and was correctly classified under sub-heading 3926.90. The appeal was rejected.