Repacking and labelling of adhesive was not manufacture where no new commodity emerged and the product's character remained unchanged.

Transferring cyanoacrylic adhesive into small metal tubes, purging the tubes with nitrogen and affixing labels was treated as repacking rather than manufacture, because the product retained the same nature and character throughout the process. The use of nitrogen and machinery was considered only preservative and did not create a new commodity. Mere labelling was also insufficient to amount to manufacture absent a deeming provision. The process therefore did not amount to manufacture.

---

---

Issues: Whether the process of transferring cyanoacrylic adhesive into small metal tubes, purging the tubes with nitrogen, and affixing labels amounted to manufacture.

Analysis: The process was found to be only repacking of the same adhesive without any change in its nature or character. The use of nitrogen and complex machinery was held to be irrelevant, because those steps merely preserved the product and did not create a different commodity. Mere labelling, by itself, was also held insufficient to constitute manufacture in the absence of a deeming provision.

Conclusion: The process did not amount to manufacture.

---