Preparation Denominated Yukinohana is a Toilet and Not Medicinal Preparation

November 29, 1960 BIR RULING NO. 526-60 The General Manager Philippine Cellulose Corporation P. O. Box 2440 M a n i l a S i r : This has reference to your request for the reconsideration of our ruling holding that the preparation denominated YUKINOHANA is a toilet and not medicinal preparation. It appears from the Report of Analysis of the Institute of Science and Technology that the preparation in question contains the following ingredients: cd Lanolin 5.3% Magnesium carbonate 25.8% Bismuth Subnitrate 2.4% Essential Oil 1.4% Base: Saponifiable matter (by diff.) 34.8% Unsaponifiable matter 23.8% Moisture content 6.5% In his certification, the Chief Drug Inspector of the Bureau of Health Services stated that the preparation contains ingredients similar to those found by the Institute of Science and Technology. He further state that bismuth subnitrate when used externally is astringent and antiseptic and is used in the treatment of acne; magnesium carbonate helps check excessive oil secretion of the skin; and anhydrous lanolin has been shown to be useful in the treatment of miliaria, an acute inflammation of the sweat glands. In a separate certification, the Chief Drug Inspector stated that YUKINOHANA is a medicinal cream intended for the relief of acne, pimples and black heads. Inasmuch as two of the proper government agencies both certify to the medicinal character of the preparation in question, this Office finds itself without alternative but to be guided by the classification given by the two competent agencies of the government. Accordingly, YUKINOHANA medicinal cream, being a medicinal and not a toilet preparation is subject to only 7% sales tax. This supersedes BIR Ruling No. 287, S. of 1960. cdta Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue