Rear Camera Integrated Module Subassembly classification confirmed as parts of mobile phones; concessional import duty available subject to IGCR compliance

Rear Camera Integrated Module Subassembly is a component incapable of independent operation and is used solely and principally with mobile phones, satisfying the twin test and the sole-and-principal test in Section Note 2(b); accordingly it is classifiable as a part of mobile phones under GIR 1 and Section Note 2(b) and thus falls under the residuary eight-digit tariff entry 8517 79 90. The subassembly is not a digital camera for heading 8525. Goods so classifiable that are for use in the manufacture of cellular mobile phones are eligible for the concessional basic customs duty at the rate specified in Sr. No. 6J of Notification No. 57/2017, subject to compliance with the IGCR Rules 2022 procedural requirements.

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Issues: (i) Whether the Rear Camera Integrated Module Subassembly exported to India merits classification under CTH 8517 79 90 of the First Schedule of the Customs Tariff; (ii) Whether the concessional basic customs duty under Sr. No. 6J of Notification No. 57/2017 is available for import of such Rear Camera Integrated Module Subassembly for use in manufacture of cellular mobile phones subject to compliance with the IGCR Rules, 2022.

Issue (i): Whether the Rear Camera Integrated Module Subassembly exported to India merits classification under CTH 8517 79 90 of the First Schedule of the Customs Tariff.

Analysis: Apply GIR 1 and Section/Chapter Notes together with HSN Explanatory Notes. The subassembly, as imported, lacks internal storage, ADC/output terminals and display/viewfinder and is non-operational until integrated with the mobile phone Main Logic Board. Section Note 2 to Section XVI must be applied sequentially; no specific four-digit heading covers the article and Section Note 2(b) governs parts suitable for use solely or principally with a particular machine. The twin test (no separate identifiable function and incapable of independent operation) confirms the article functions only when integrated in the mobile phone and is tailor-made for specific phone models. Therefore it is appropriately treated as a part of mobile phones and falls within the residual parts entry of heading 8517 at eight-digit level.

Conclusion: The Rear Camera Integrated Module Subassembly is classifiable under CTH 8517 79 90.

Issue (ii): Whether the concessional basic customs duty under Sr. No. 6J of Notification No. 57/2017 applies to the Rear Camera Integrated Module Subassembly when imported for use in the manufacture of cellular mobile phones.

Analysis: Sr. No. 6J of Notification No. 57/2017 specifies concessional BCD for goods classifiable under 8517 79 90 used in manufacture of cellular mobile phones, subject to compliance with the IGCR Rules, 2017 (as amended 2022). Having held the product classifiable under 8517 79 90 and that it is an essential part for manufacture of mobile phones, the article falls within the scope of the notification, subject to procedural compliance under the IGCR Rules.

Conclusion: The concessional BCD benefit under Sr. No. 6J of Notification No. 57/2017 is available for the Rear Camera Integrated Module Subassembly when imported for use in manufacture of cellular mobile phones, subject to compliance with the IGCR Rules, 2017 (as amended 2022).

Final Conclusion: The Authority rules that the Rear Camera Integrated Module Subassembly is a part of cellular mobile phones classifiable under CTH 8517 79 90 and eligible for the concessional BCD under Sr. No. 6J of Notification No. 57/2017 on fulfillment of the applicable IGCR procedural conditions.

Ratio Decidendi: Parts which are suitable solely or principally for use with a particular kind of machine and incapable of independent operation are to be classified with that machine under Section Note 2(b) to Section XVI, rendering the Rear Camera Integrated Module Subassembly classifiable under heading 8517 79 90 and eligible for notification-based concessional duty subject to prescribed procedural compliance.

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