Definition
Manufactured articles are goods or commodities that have been transformed from raw or natural materials into a new form through human labor, mechanical process, or industrial production, resulting in a product with a distinct character, use, or commercial identity from the source material.
The term appears most frequently in two legal contexts:
1. Tariff and customs law: Articles subjected to a manufacturing process that gives them a new name, character, or use are classified as "manufactured" for purposes of import duties, distinguishing them from raw materials or unprocessed goods. The line between a processed raw material and a manufactured article has been a persistent question in tariff classification.
2. Patent law: "Manufacture" (or "manufactured article") is one of the four statutory categories of patentable subject matter. In this context, a manufactured article is a tangible object produced by human effort—distinct from a process, machine, or composition of matter—though courts have often treated these categories with flexibility.
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Common Language
Modern common usage (Wiktionary): "Manufactured" typically means produced by large-scale industrial methods; a "manufactured article" in everyday speech is simply a factory-made product.
Historical common usage (Webster's 1913): Webster's defined "manufacture" as "the operation of making wares or any products by hand, by machinery, or by other agency; the production of articles for use from raw or prepared materials by giving to these materials new forms, qualities, properties, or combinations, whether by hand-labor or by machinery."
The common understanding tracks the legal concept more closely here than in many terms, but the legal usage adds significant precision: not every physical change constitutes manufacture for legal purposes. Courts and tariff boards have drawn careful distinctions about whether a process has produced something sufficiently new in character and use—a question ordinary language does not resolve.
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Common Confusion
The term is sometimes used loosely to mean any product of human labor, which can blur important legal distinctions. In patent law, a manufactured article overlaps with—but is not identical to—a "machine" (which has interacting moving parts) or a "composition of matter" (a chemical combination). In tariff law, a "manufactured article" must be distinguished from a partially processed material that has not yet acquired a distinctive new identity. The legal question is not merely whether something was made in a factory but whether the transformation is legally sufficient to change its classification.
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Why It Matters in Research
Researchers working in the Law Mind corpus will encounter "manufactured articles" primarily in two areas, and the analytical framework differs between them.
In tariff and customs sources, the term is intensely fact-specific. Bouvier's illustrates this well: kindling wood produced by machinery from green slabs, India rubber shaped into shoe forms, animal charcoal, bone black, cut coral, and reeds all generated separate classification disputes. Historical sources in this area are best read as snapshots of administrative and judicial decision-making about specific commodities, not as providing a transferable general rule. The principle underlying these cases—whether the article has acquired a new name, character, or use—is the durable analytical hook, but its application shifts with the commodity.
In patent law, the statutory category "manufacture" has been relatively stable in text but has been contested at the margins. Researchers examining historical patent treatises and cases should note that the four-category framework (process, machine, manufacture, composition of matter) was codified in the Patent Act of 1952 but reflects much older common law and statutory antecedents. Modern debates about software, business methods, and biotechnology often circled back to whether a claimed invention qualified as a manufacture or fell outside patentable subject matter entirely.
Researchers should be alert to the possibility that a historical source using "manufactured articles" in a tariff context will not translate cleanly into patent doctrine, and vice versa. The phrase is the same; the legal test and consequences are different.
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Historical Dictionary Support
Bouvier's Law Dictionary addresses "manufactured articles" almost entirely through tariff classification examples, reflecting the period's primary litigation context for the term. The entry proceeds by enumeration—listing commodities that courts and customs authorities held to be or not to be "manufactured"—rather than by stating a general principle. This is a useful reminder that nineteenth-century legal dictionaries often functioned as case digests for specific commercial disputes rather than as sources of doctrinal synthesis.
The examples Bouvier's provides (kindling wood from green slabs, India rubber shaped into shoes, animal charcoal and bone black, cut coral, reeds) cluster around the transformation question: has the raw material been changed enough to be a new commercial article? What Bouvier's does not provide is a clear negative test or a discussion of borderline cases that were held not to constitute manufacture. Researchers should treat the Bouvier's entry as a pointer to primary sources rather than a definitive statement of doctrine.
No significant divergence exists across available historical dictionary sources on the core concept, though the term's patent law dimension receives more systematic treatment in later treatises than in the dictionary literature.
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Jurisdictional Note
In federal tariff and customs law, classification of manufactured articles is governed by federal statute and international treaty frameworks, making jurisdiction largely uniform at the federal level. In patent law, "manufacture" is equally a federal question. State law uses of the term—in commercial codes, product liability statutes, and consumer protection regulations—vary and may define "manufactured product" or "manufacturer" differently than the tariff or patent frameworks do.
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Encyclopedia Cross-Reference
Products Liability — Manufacturing Defects (The Law Mind Torts & Personal Injury Encyclopedia)
Products Liability — Component Part Manufacturer Liability (The Law Mind Torts & Personal Injury Encyclopedia)
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