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<h1>Tariff classification of flat-rolled stainless-steel decorative wall panels assigned to other flat-rolled stainless-steel products under heading 7219.</h1> Classification dispute over imported architectural decorative wall panels manufactured from flat-rolled stainless-steel sheets: panels are not structural ... Tariff classification of goods - flat-rolled stainless-steel products - structures and parts of structures - residuary classification: other articles of iron or steel - General Rules for the Interpretation of the Import Tariff - Classification of the imported Architectural Decorative Designer Wall Panel Articles of stainless steel under the Customs Tariff - HELD THAT:- Applicant has restricted the question for advance ruling to classification under Headings 7308 and 7326. However, it is a settled position of law that the Authority for Advance Rulings is not bound by the tariff headings suggested by the Applicant and is required to determine the correct classification in accordance with the Customs Tariff Act. 1975, the General Rules for Interpretation and existing legal positions in terms of relevant case laws. The subject goods are manufactured from flat- rolled stainless-steel sheets. These sheets are cold-rolled and thereafter subjected to cutting to size and various surface finishing processes such as mirror polishing, hairline finish, satin finish. embossing, etching, vibration finish, sand blasting, anti-fingerprint coating and Physical Vapour Deposition (PVD) coating. Protective PVC film is applied to prevent surface damage during transportation and handling. The goods are imported in the form of flat panels of stainless-steel having uniform thickness, ranging approximately from 0.4 mm to 3 mm, and supplied in rectangular, square, circular or triangular shapes. Notwithstanding the surface finishing and decorative treatments, the essential character of the goods remains that of flat-rolled stainless-steel products. Applicability of Heading 7308. Heading 7308 covers structures and parts of structures of iron or steel. As clarified in the HSN Explanatory Notes, this heading applies to goods which are identifiable as structures or parts of structures performing a structural or constructional function. I find that the subject goods are not beams, columns, frames, trusses or other structural components. Mere use of flat stainless-steel sheets for cladding or decorative applications on walls, facades or interiors does not render them parts of structures for the purpose of Heading 7308. Accordingly, classification under Heading 7308 90 90 is not tenable. Applying Rule 1 of the General Rules for Interpretation, classification is to be determined according to the terms of the headings and the relevant Section and Chapter Notes. As the subject goods are flat-rolled products of stainless steel, they are squarely classifiable under Heading 7219. The application of Rule 3 does not arise in the present case. Applying Rule 6 at the sub-heading level, the appropriate classification is under Customs Tariff Heading 7219 90 90. The goods proposed to be imported by the Applicant are correctly classifiable under Customs Tariff Heading 7219 90 90 and not under I leadings 7308 or 7326 as claimed by the Applicant. Issues: Whether goods described as 'Architectural Decorative Designer Wall Panel Articles of Stainless Steel of different shapes, sizes and finishes with or without drilled holes in corners' are classifiable under Customs Tariff Heading 7308 90 90 or 7326 90 60 as contended by the applicant, or under another heading of the Customs Tariff Act, 1975.Analysis: The Authority examined the product description, manufacturing process, dimensions (thickness range 0.4 mm to 3 mm), surface treatments (polishing, embossing, etching, PVD coating, PVC lamination etc.), and applicable statutory and explanatory provisions including Chapter 72 notes and HSN Explanatory Notes. The Authority applied the General Rules for the Interpretation of the Import Tariff, observing that the finishing operations enhance appearance or properties but do not alter the fundamental identity of the goods. Chapter 72 Note 1(k) and the Explanatory Notes treat perforated, polished or coated flat-rolled products as remaining flat-rolled products provided they do not assume the character of articles of other headings. The Authority found that the panels retain the essential character of flat-rolled stainless-steel products and are not structural components (beams, columns, frames) falling under Heading 7308, nor are they residuary 'other articles' under Heading 7326 where a more specific heading (7219) applies. Rule 1 and Rule 6 of the GIR were applied to determine the appropriate heading at the sub-heading level.Conclusion: The goods are classifiable under Customs Tariff Heading 7219 90 90 as 'Other flat-rolled products of stainless steel' and not under Headings 7308 90 90 or 7326 90 60.