Plastic seedling trays classified as articles of plastics, not agricultural implements, for GST purposes.

Plastic agricultural seedling trays made wholly of polypropylene were not agricultural implements under Chapter 82 because that chapter covers base-metal tools and implements with a working part of base metal or similar material. Applying the General Rules for Interpretation and the relevant tariff notes, the trays were treated as articles of plastics under Chapter 39, with heading 3926 covering other plastic articles not elsewhere specified. The trays were therefore classified under CTH 39269099 and subjected to GST under the applicable Schedule III entry.

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Issues: Whether plastic agricultural seedling trays are classifiable under Chapter 82 as agricultural implements or under Chapter 39 as articles of plastics, and the applicable GST rate thereon.

Analysis: The classification had to be determined by applying the General Rules for Interpretation and the relevant section and chapter notes of the Customs Tariff Act, 1975 as made applicable by the GST notification. Chapter 82 covers tools and implements of base metal and requires a working part of base metal or similar material. The trays in question were made wholly of polypropylene plastic and were neither base-metal tools nor parts or accessories of any agricultural machinery. They were used to grow and transport seedlings, but the trays themselves did not become machinery parts by reason of such use. Chapter 39 covers plastics and articles thereof, and heading 3926 extends to other plastic articles not elsewhere specified or included.

Conclusion: The trays are classifiable under CTH 39269099 as articles of plastics and are liable to GST at 9% CGST and 9% SGST under the relevant Schedule III entry.

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