PVC raincoat classification turns on material composition, with non-woven PVC articles falling under plastic tariff heading.

PVC raincoats made from non-woven PVC sheets assembled by fusion are classifiable under HSN 3926 as plastic articles, not under HSN 6201 as textile articles, because material composition and tariff description govern classification rather than apparel use alone. The ruling held that Chapter 62 applies to made-up articles of textile fabric, which these raincoats were not. Having classified the goods under Heading 3926, the applicable GST rate followed the corresponding entry in Schedule III of Notification No. 01/2017-Central Tax (Rate), resulting in the rate prescribed for plastic raincoats under that heading.

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Issues: (i) Whether PVC raincoats are classifiable under HSN 6201 as textile articles or under HSN 3926 as plastic articles; (ii) Whether PVC raincoats attract GST at the rate applicable to Heading 3926.

Issue (i): Whether PVC raincoats are classifiable under HSN 6201 as textile articles or under HSN 3926 as plastic articles

Analysis: The product was found to be made from PVC sheets assembled by fusion, resulting in a non-woven article. Chapter 62 applies to made-up articles of textile fabric, whereas the PVC sheet used for the raincoat was not regarded as a woven or textile fabric. The exclusions in Chapter 39 and Section XI did not assist the applicant on the facts. The Authority also applied the principle that the product's material composition and tariff description, rather than commercial apparel use alone, determine classification in this case.

Conclusion: PVC raincoats are classifiable under HSN 3926 and not under HSN 6201.

Issue (ii): Whether PVC raincoats attract GST at the rate applicable to Heading 3926

Analysis: Once the goods were held to fall under Heading 3926, the applicable rate followed the entry in Schedule III of Notification No. 01/2017-Central Tax (Rate) dated 28.06.2017, as amended, which covers plastic raincoats under the said heading.

Conclusion: PVC raincoats attract GST at the rate applicable to Heading 3926, namely 18% under the relevant entry.

Final Conclusion: The advance ruling confirms classification of the applicant's PVC raincoats as plastic articles under Heading 3926, with the corresponding GST rate applicable under the notified schedule entry.

Ratio Decidendi: A PVC raincoat made from non-woven PVC sheets is not a textile article merely because it is worn as apparel; where the material and tariff notes place it outside Chapter 62, classification follows the specific heading covering plastic articles.

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