Classification of cotton linters depends on whether pulping causes fundamental transformation, altering tariff heading accordingly. Classification of cotton linters after processing depends on the method used: raw, cleaned, bleached or rendered absorbent linters remain under Heading 1401, but where linters are subjected to alkaline cooking/digestion (pulping) that solubilises non cellulosic materials and yields a purified cellulose product, they are classifiable as cotton linter pulp under Heading 4701. Processes that do not produce such a fundamental transformation do not attract additional excise beyond the treatment applicable to bleached cotton linters.
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Provisions expressly mentioned in the judgment/order text.
Classification of cotton linters depends on whether pulping causes fundamental transformation, altering tariff heading accordingly.
Classification of cotton linters after processing depends on the method used: raw, cleaned, bleached or rendered absorbent linters remain under Heading 1401, but where linters are subjected to alkaline cooking/digestion (pulping) that solubilises non cellulosic materials and yields a purified cellulose product, they are classifiable as cotton linter pulp under Heading 4701. Processes that do not produce such a fundamental transformation do not attract additional excise beyond the treatment applicable to bleached cotton linters.
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