Repacking from bulk to retail packs not treated as manufacture where goods arrive in tankers rather than bulk packs. The circular states that whether labelling or repacking amounts to manufacture under Chapter Note 10 depends on whether the original conveyance is a bulk pack; it applies Tribunal precedent holding that goods received in tankers are not bulk packs, so transferring goods from tankers into smaller drums does not amount to repacking from bulk packs to retail packs and thus does not attract the fiction of manufacture.