"Indra Smart Pro" EVSE Classified Under Customs Tariff Act

The final ruling classified the "Indra Smart Pro" EVSE under sub-heading 8537 10 00 of the Customs Tariff Act, 1975. The device was deemed to control and distribute electricity without converting it, aligning with the description of devices covered under Heading 8537 for electric control or distribution of electricity. The decision was supported by the device's features, including safety functionalities and smart controls, similar to a US Customs ruling on a comparable electric vehicle charging station.

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Issues Involved:
1. Classification of "Indra Smart Pro" EVSE (Electrical Voltage Supply Equipment) for customs purposes.

Issue-Wise Detailed Analysis:

1. Classification of "Indra Smart Pro" EVSE:

Applicant's Position:
- The applicant, M/s. Gulf Oil Lubricants India Ltd., proposed to import "Indra Smart Pro" and sought an advance ruling on its classification under Heading 8543.
- The device provides electric power to the charger onboard an EV, recharging the vehicle's batteries. It includes features like all-weather functioning, app control, smart scheduling, solar charging, off-peak charging, house fuse protection, quick boost, and Over-The-Air (OTA) updates.
- The applicant argued that since EVSE systems are not specifically covered under any chapter, they should be classified under Heading 8543, which covers electrical machines and apparatus with individual functions not specified elsewhere.

Jurisdictional Commissioner's Position:
- The Commissioner of Customs (Import), Air Cargo Complex, Sahar, suggested that the device should be classified under Tariff Heading 8504 40 30, which covers battery chargers, including EV battery chargers, as Heading 8543 is a residual heading and cannot be considered when a specific heading exists.
- The Commissioner argued that the device is a feature-rich EV charger and thus falls under the specific heading for battery chargers.

Applicant's Rejoinder:
- The applicant reiterated that the device is akin to EVSE and argued that Heading 8504 involves apparatus that convert electrical energy, which their device does not do.
- They emphasized that the device only supplies electricity without converting the current or altering the frequency, thus should not fall under Heading 8504.

Personal Hearing:
- During the personal hearing, the applicant's representatives explained that the device supplies AC power from the grid to the vehicle's charger without converting AC to DC.
- They highlighted the smart features of the device and clarified that it requires manual intervention to start supplying electricity and can draw power from a solar supply after conversion from DC to AC.

Authority's Analysis:
- The authority considered the submissions, comments, and additional information from reliable sources, focusing on the classification of the Indra Smart Pro.
- The device supplies AC power from the grid/solar module to the charger onboard the vehicle without converting the AC supply to DC. It also includes features like protective earth, neutral faults, earthling faults, simultaneous contact risks, touch voltage risks, DC leakage, and load curtailment.
- The authority noted that the device incorporates necessary additional apparatus such as circuit boards, relays, and contactors, which are used for making and breaking electrical circuits.

Classification Decision:
- Heading 8504: The authority found that the device does not convert electrical energy and merely supplies AC power, making it unsuitable for classification under Heading 8504, which covers electrical transformers, static converters, and inductors.
- Heading 8543: The applicant's suggested classification under Heading 8543 was considered. However, since the device has an individual function and its functions are covered under Heading 8537, it was necessary to examine Heading 8537.
- Heading 8537: This heading covers boards, panels, consoles, desks, cabinets, and other bases equipped with two or more apparatus for electric control or distribution of electricity. The device under consideration fits this description as it controls and distributes electricity, provides safety features, and includes smart functionalities like app control and smart scheduling.
- US Customs Ruling: The authority referenced a similar ruling by US Customs, which classified a comparable electric vehicle charging station under Heading 8537, emphasizing that such devices control and distribute electricity without converting it.

Final Ruling:
- The authority ruled that the "Indra Smart Pro" (Electrical Voltage Supply Equipment) merits classification under sub-heading 8537 10 00 of the First Schedule to the Customs Tariff Act, 1975, as it fits the description of devices covered under this heading for electric control or distribution of electricity.

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