Tariff classification of partially skimmed sweetened condensed milk follows Chapter Note expansion, placing it under condensed milk.

Partially skimmed sweetened condensed milk is classifiable under sub-heading 0401.14 as concentrated (condensed) milk, not under the residuary sub-heading 0401.19. The tariff description was read with the Chapter 4 note, the milk definition, the IS specification for condensed milk, and the food standards under the Prevention of Food Adulteration Rules, 1955. Because the chapter note expressly expands the meaning of condensed milk to include products made from full cream, partially skimmed, or skimmed milk, classification had to follow that broader tariff meaning rather than a pre-note understanding of the commodity. Earlier precedents were distinguished as arising in different tariff contexts or involving separate commercial identity.

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Issues: Whether partially skimmed sweetened condensed milk is classifiable under sub-heading 0401.14 as concentrated (condensed) milk or under sub-heading 0401.19.

Analysis: The product was compared with the relevant tariff description, the chapter note defining milk, the IS specification for condensed milk, and the food standards under the Prevention of Food Adulteration Rules, 1955. The decisive consideration was that condensed milk includes products made from full cream, partially skimmed, or skimmed milk and that the chapter note to Chapter 4 governs the expression used in the tariff. The cited precedents were distinguished because they arose in a different tariff context or concerned a product shown to have separate commercial recognition.

Conclusion: Partially skimmed sweetened condensed milk falls within sub-heading 0401.14 and not the residuary sub-heading 0401.19.

Ratio Decidendi: Where a chapter note expressly expands the meaning of a tariff description, classification must follow that note and the commercial identity of the product within the tariff scheme, not the pre-note understanding of the commodity.

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