Assessable value includes dies and similar manufacturing tools, with their cost apportioned across the goods produced.

The cost of dies, tubes, cylinders and similar tools used in manufacturing was treated as includible in assessable value. Where such items were used over a considerable period and across a large quantity of goods, their cost had to be apportioned to the final products. The analysis followed earlier Tribunal authority on cylinders used for printed HDPE pouches and applied the same principle to tools or dies, confirming inclusion for valuation purposes and corresponding apportionment.

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Issues: Whether the cost of dies, tubes, cylinders or other tools used in the manufacture of the final product was includible in the assessable value and, if so, whether such cost had to be apportioned over the goods manufactured.

Analysis: The issue was treated as settled by the earlier Tribunal decision holding that the cost of cylinders used in the manufacture of printed HDPE pouches formed part of the assessable value. Since the use of such items extended over a considerable period and a large quantity of goods, their cost was required to be apportioned to the goods manufactured. The earlier appellate finding that the cost of tools or dies was includible for purposes of apportionment was also followed.

Conclusion: The cost of dies, tubes or similar tools was held includible in the assessable value, with apportionment to the final products.

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