Reactor in Hand Pumps: GST Classification Decision

The Authority determined that the Reactor used in Hand Pumps for water disinfection is not classified as part of the hand pump but rather under Tariff Heading 8421 21 90 for filtering or purifying machinery. Consequently, the Reactor is subject to a GST rate of 9% CGST and 9% SGST.

---

---

Issues Involved:
1. Classification of goods (i.e., Reactor used in Hand Pump for water disinfection).
2. GST Rate Applicability on reactor machine used in Hand Pump for water disinfection.

Detailed Analysis:

1. Classification of Goods:
The applicant, a manufacturer of Reactors used in Hand Pumps for water disinfection, sought classification under HSN No. 8413, 8413 91 as Hand pumps and parts thereof. The applicant argued that the Reactor, which harnesses fluid dynamics to kill microbes in water, should be classified as part of the hand pump because it forms an integral part of the system.

The concerned officer contended that the classification cannot be based solely on the end use of the product. The officer emphasized the need for details like design, characteristics, and functions to determine the correct classification. The officer also noted that the Reactor, despite being used with hand pumps, has a distinct function of purifying water, which differs from the primary function of a hand pump (i.e., lifting water from underground). Therefore, the Reactor should not be classified under Chapter Heading 8413 but more appropriately under Chapter Heading 8419.

Upon review, the Authority observed that the Reactor is not an essential part of the hand pump since the hand pump can function without it. The Reactor’s primary function is water purification, which is distinct from the hand pump’s function of water withdrawal and delivery. The Authority concluded that the Reactor, having an independent identity and function, should not be classified as a part of the hand pump.

2. GST Rate Applicability:
The applicant proposed that the Reactor should attract the GST rates applicable to hand pumps and their parts. However, the Authority found that the Reactor’s primary function is water purification, which aligns with the description under Tariff Heading 8421.21.90 – "Filtering or purifying machinery and apparatus for liquids."

The Authority referred to the GST Tariff, which lists the following under Heading 8421:
- 8421 21 90: Other filtering or purifying machinery and apparatus for liquids, attracting 9% CGST and 9% SGST.

The Authority concluded that the Reactor used by the applicant in hand pumps for water purification is classifiable under Tariff Heading 8421 21 90 and is liable to GST at the rate of 9% CGST and 9% SGST.

Order:
1. Classification of Goods: The Reactors are classifiable under Tariff Heading 8421 21 90 of the GST Tariff.
2. GST Rate Applicability: The applicable GST rate is 9% CGST and 9% SGST on the Reactor used in Hand Pumps for water disinfection.

---