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Issues: (i) Classification of 24 listed components/parts of an e-Motor for use with a 3-in-1 e-Axle of electric vehicles under the Customs Tariff / HSN; (ii) Applicant's request to keep the advance ruling confidential.
Issue (i): Classification of the listed parts of the e-Motor (24 items) under appropriate HSN/CTH codes.
Analysis: The Authority applied the General Rules for Interpretation (GRI), relevant Section and Chapter notes, and HSN explanatory notes. It held that the e-Motor itself is excluded from Chapter 87 by Note 2(f) to Section XVII and therefore falls under Chapter 85, specifically heading 8501 for electric motors (85015290 for the motor). For parts, Note 2 to Section XVI is applied sequentially: parts that are goods covered by headings in Chapter 84 or 85 are classified in those headings (Note 2(a)); other parts suitable solely or principally with machines of a heading are classified with those machines or in heading 8503 (Note 2(b)); remaining parts go to residual headings (Note 2(c)). The Authority examined each of the 24 items against these rules and explanatory notes and determined specific sub-headings (for example, stator/rotor/inner housing/share housing/vent/protection cap/plug/coolant connector under 85030029; insulating roll under 39219096; connectors/terminal board under 85369090; bearings under 84821051; magnets under 85051190; resolver rotor and stator under 85043100; powder coating under 39073010; seals under 40169330; washers and retaining rings as parts of general use under 73182100 / 73182990; cable tie under 39269099). The Authority relied on Note 1 exclusions to Section XVI, Section XV note on parts of general use, and HSN explanatory notes to justify placement of items in their own headings where applicable.
Conclusion: The listed parts are classified as set out in Table-III of the ruling (examples: stator package, rotor package, inner housing, etc. CTH 85030029; insulating roll CTH 39219096; connector ring/terminal board CTH 85369090; bearings CTH 84821051; magnets CTH 85051190; resolver set CTH 85043100; powder coating CTH 39073010; double seal CTH 40169330; spring washer CTH 73182100; retaining rings CTH 73182990; cable tie CTH 39269099).
Issue (ii): Whether the applicant's request to keep the advance ruling confidential should be accepted.
Analysis: Regulation 27 of the Customs Authority for Advance Rulings Regulations, 2021 and the amended notification were considered. The Authority examined the ruling content and found no technical specifications, proprietary content, or commercially sensitive information warranting confidentiality. The applicant did not provide specific supporting grounds for confidentiality.
Conclusion: The request for confidentiality is refused; the ruling will not be kept confidential.
Final Conclusion: The Authority has granted the applicant's classification requests by assigning definitive HSN/CTH codes to each of the 24 listed parts in favour of the applicant, and has denied the confidentiality request; the advance ruling therefore issues with the stated classifications available publicly.
Ratio Decidendi: Where an electrical machine or its parts are excluded from Section XVII as electrical machinery (Note 2(f) to Section XVII), classification follows Chapter 85 headings for the machine itself and Note 2 to Section XVI applied sequentially determines whether individual parts fall in specific Chapter 84/85 headings, in heading 8503 as parts suitable solely or principally with motors, or in other appropriate headings; parts of general use are excluded from Section XVI and classified in their own material headings.
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