Plastic-processing machinery classification prevailed where the plant manufactured HDPE tapes and ropes from plastic granules.

Classification of a rafia tape plant depended on the nature of the raw material and the products manufactured. Because the machine used plastic granules and produced HDPE tapes and ropes from plastic material, the goods were treated as products of plastic rather than textile articles. On that basis, the plant fell within the heading for machinery for working plastics or for manufacturing products from plastics, and not within the heading for machinery for extruding or processing man-made textile materials. The classification adopted by the Revenue was upheld and the competing textile-based classification was rejected.

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Issues: Whether the rafia tape plant used for manufacturing HDPE tapes and ropes was classifiable under Heading 84.44 as machinery for extruding, drawing, texturising or cutting man-made textile materials, or under Heading 84.77 as machinery for working plastics or for the manufacture of products from plastics.

Analysis: The classification turned on the character of the goods produced by the machine and the nature of the raw material used. HDPE strips and tapes were treated as goods made of plastic and, therefore, not as textile articles falling under Headings 54 and 56. Since the appellants admitted that plastic granules were the raw material and the machine produced HDPE tapes and ropes from plastic materials, the machine answered the description of machinery for working plastics or for the manufacture of products from those materials.

Conclusion: The machine was correctly classifiable under Heading 84.77 and not under Heading 84.44.

Final Conclusion: The appeal failed and the classification adopted by the Revenue was upheld.

Ratio Decidendi: Where a machine manufactures products from plastic raw material, its classification is governed by the heading covering machinery for working plastics or for manufacture of products from plastics, even if the finished goods are claimed to have textile-like characteristics.

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