Purification of used oil is not manufacture where the process only removes impurities and makes it reusable.

Purification of used lubricating and mineral oils by acid or alkali treatment and filtration through fuller's earth, where the process only removes impurities and renders the oil reusable, does not amount to manufacture. The analysis applies prior Tribunal rulings that purification of used oil with acid and activated earth, and reclamation of transformer oil, are not manufacturing processes. On that principle, conversion of the used oil into reusable white oil remains a treatment of an existing product rather than the creation of a new marketable article.

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Issues: Whether treatment of used lubricating and mineral oils by acid or alkali and filtration through fuller's earth, resulting in reusable white oil, amounts to manufacture.

Analysis: The activity consisted of removing impurities from used oil so that it could be rendered fit for use again. Prior Tribunal decisions had held that purification of used oil with acid and activated earth does not by itself amount to manufacture, and that reclamation of transformer oil is likewise not manufacture. The same principle applied to the process in question.

Conclusion: The activity does not amount to manufacture and the appeal succeeds.

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