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Issues: (i) Whether PVC/plastic raincoats are classifiable under Chapter 39 as articles of plastics or under Chapter 62 as articles of apparel and clothing accessories; (ii) what rate of GST is leviable on PVC/plastic raincoats.
Issue (i): Whether PVC/plastic raincoats are classifiable under Chapter 39 as articles of plastics or under Chapter 62 as articles of apparel and clothing accessories.
Analysis: Chapter 39 expressly covers articles of plastics and the explanatory notes to heading 3926 include articles of apparel and clothing accessories made by sewing or sealing sheets of plastics, including raincoats. The product in question is manufactured from PVC sheets and the parts are heat-welded or chemically bonded, so it is not a woven textile fabric. Chapter 62 applies only to made up articles of textile fabric, and the claim that PVC raincoats are man-made fibre textile material was not accepted.
Conclusion: PVC/plastic raincoats are classifiable under HSN 3926 in Chapter 39 and fall under Entry No. 127 of Notification No. 9/2025-CT (R) dated 17.09.2025.
Issue (ii): What rate of GST is leviable on PVC/plastic raincoats.
Analysis: Once the goods are classified under Chapter 39, the applicable rate follows the entry prescribed for other articles of plastics rather than the concessional rate applicable to Chapter 62 apparel. On that classification, the product attracts GST at the rate prescribed for the relevant Chapter 39 entry.
Conclusion: The GST rate leviable on PVC/plastic raincoats is 18%.
Final Conclusion: The ruling rejects the applicant's claimed Chapter 62 classification and confirms taxability under Chapter 39 with the corresponding higher rate of GST.
Ratio Decidendi: PVC raincoats made from sealed or welded plastic sheets are classifiable as articles of plastics under Chapter 39 because Chapter 62 applies only to made up articles of textile fabric.
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