Classification of Electronic Power Steering-Electronic Control Unit (EPS-ECU) as Automobile Parts Upheld

The Hon'ble CESTAT, Principal Bench, New Delhi, in Mitsubishi Electric Automotive India Pvt Ltd. Versus Commissioner Of Customs, New Delhi - 2026 (3) TMI 1652 - CESTAT NEW DELHI held that Electronic Power Steering-Electronic Control Units (EPS-ECU) and their parts are correctly classified as parts of a power steering system under Customs Tariff Item (CTI) 8708 94 00, and not as independent electronic instruments or apparatus.

Facts:

• The appellant, M/s Mitsubishi Electric Automotive India Pvt Ltd., imported goods under 196 Bills of Entry filed between March 2022 and September 2022.
• The Commissioner of Customs (Appeals), New Delhi, via an order-in-appeal dated 04.10.2024, upheld the assessment classifying the imported EPS-ECUs under CTI 8708 94 00.
• The appellant filed 196 appeals to challenge this classification, praying that the goods be classified under CTI 9032 90 00, with alternative claims for CTI 8537 10 00 or CTI 8543 70 99. The appellant relied on a Chennai bench order (Hyundai Motors Ltd.) that classified certain ECUs under CTH 9032.

Issues:

• Whether the Electronic Power Steering-Electronic Control Unit (EPS-ECU) and its constituent parts merit classification under Chapter 90 (CTI 9032 90 00) as instruments/apparatus?

Held:

The Hon'ble CESTAT, Principal Bench, New Delhi, in Mitsubishi Electric Automotive India Pvt Ltd. Versus Commissioner Of Customs, New Delhi - 2026 (3) TMI 1652 - CESTAT NEW DELHI held as under:

• Noted that the EPS-ECU is not an instrument or an apparatus, but rather a specific part of the power steering system of an automobile.
• Form Does Not Dictate Function: Merely being in the form of a Printed Circuit Board (PCB) with other electronic components does not change its nature from an automobile part to an independent instrument or apparatus.
• Core Function: It acts as a microprocessor that receives information from sensors to process and issue instructions, regulating the assistance provided by the power steering to the driver. Therefore, it does not fall under CTI 9032 90 00.
• Alternative Claims Rejected: The EPS-ECU is not designed for general electricity distribution or electric control, nor is it a residual electrical machine; therefore, it cannot be classified under CTI 8537 10 00 or CTI 8543 70 99.
• Classification of Parts: Since the EPS-ECU itself does not merit classification under the headings proposed by the appellant, its sub-assemblies and child parts also do not fall under those respective headings (CTI 9032 89 90, 8538 90 00, or 8543 90 00).
• The appellant relied on a Chennai bench order (Hyundai Motors Ltd.) that classified certain ECUs under CTH 9032.
• However, the Tribunal noted that the Chennai bench itself distinguished between different types of ECUs, stating that 'ECU' is a generic name and each ECU must be considered on its own merits for classification. The appellant appealed the earlier Tribunal order to the Supreme Court, but no stay was granted, meaning the previous decision remained binding.

Relevant Tariff Items Discussed:

• CTI 8708 94 00: Parts and accessories of the motor vehicles of headings 8701 to 8705 (Steering wheels, steering columns and steering boxes; parts thereof). (Upheld Classification)
• CTI 9032 90 00 / 9032 89 10: Automatic regulating or controlling instruments and apparatus. (Rejected Classification)