Tariff classification of coir felt sheets turns on essential character, placing the composite product under HSN 9404 90 00 with 12% GST.

Coir felt sheets made from coir fibre with low melt polyester fibre as a binder were classified by their essential character, commercial identity and manufactured nature. The composite sheet was not treated as a simple coir yarn article under HSN 5609 00 10, nor as a finished bedding or furnishing article under the excluded higher-rate entries. Instead, it was held to fall under HSN 9404 90 00 as a coir-based felt/sheet, making GST payable at 12%. The ruling also noted that decisions concerning coir yarn were inapplicable because the product in dispute was a manufactured felt sheet, not yarn.

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Issues: Whether coir felt sheets manufactured from coir fibre and low melt polyester fibre are classifiable under HSN 5609 00 10 as products of coir, or under HSN 9404 90 00, and the applicable rate of GST.

Analysis: The product was found to be a thermally bonded composite sheet made predominantly of coir fibre with low melt polyester fibre used as a binder. Classification was determined by the product's essential character, use and commercial identity, together with the relevant tariff entries, chapter notes and explanatory notes under the GST rate notification. The product was held not to be a simple coir yarn article under heading 5609 and not to be a finished bedding or furnishing article under the excluded higher-rate entries, but a coir-based felt/sheet more appropriately falling in heading 9404. The applicant's reliance on the cited coir-yarn decisions was held inapplicable because the present dispute concerned a manufactured coir felt/sheet rather than yarn.

Conclusion: The coir felt/sheets are classifiable under 8 digit HSN Code 9404 90 00 and attract GST at 12%.

Ratio Decidendi: For tariff classification, the product must be placed according to its essential character and commercial identity, and a coir-based thermally bonded sheet is classifiable under the heading that best describes its manufactured nature rather than as a simple coir yarn product.

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