Tariff classification of cotton swabs turned on manufacture, character and use, placing them under textile wadding, not brushes.

Cotton swabs were analysed for tariff classification by reference to their manufacture, character and intended use. Because they were made from cotton slivers and answered the description of articles of wadding of textile materials, they fell under Chapter Heading 56.01. They did not qualify as brooms or brushes under Chapter Heading 96.03 merely because they were used for cleaning dirt and wax from ears and allied applications. The stated conclusion was that classification under Chapter Heading 56.01 was correct.

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Issues: Whether cotton swabs were classifiable under Chapter Heading 56.01 as wadding of textile materials and articles thereof, or under Chapter Heading 96.03 as brooms or brushes.

Analysis: The product was examined with reference to the tariff headings, the process of manufacture, and its intended use. Chapter Heading 56.01 covers wadding of textile materials and articles thereof. The product was made from cotton slivers and the manufacturing process showed conversion into an article of wadding of textile materials. Chapter Heading 96.03 covers brooms and brushes, and cotton swabs did not answer that description. Their use for cleaning dirt and wax from ears, and for allied applications, supported classification by reference to their character as manufactured textile wadding rather than as brooms or brushes.

Conclusion: Cotton swabs were correctly classifiable under Chapter Heading 56.01 and not under Chapter Heading 96.03, and the appeal succeeded in favour of the Revenue.

Ratio Decidendi: Tariff classification is determined by the product's manufacture, character, and end use, and a textile wadding article cannot be classified as a broom or brush merely because it is used for cleaning.

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