AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
2025 (12) TMI 1014
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....r the products. The List of products for which classification is sought is as under: Sr. No. Description of Paper Product HSN Declared Specification 1. Bamboo Pulp Mother Roll Serving Napkin 1 Ply for SN100 48030010 1 Ply*17- 7.5GSM, 280mm*1100mm Bamboo Pulp Unbleached Roll Dia 1100mm Core 7.6cm Pe Bags Wrapped 2. Bamboo Pulp Mother Roll Kitchen Towel Single Use 1430 mm 48030010 Unbleached Bamboo Pulp GSM:17g Diameter: 1150mm 3. Bamboo Pulp Mother Roll Kitchen Towel Reusable 910 mm 48030010 110 GSM 910mm Needlepunched Novwovens Jumbo 4. Bamboo Pulp Mother Roll Toilet Paper 1400mm 3 Ply 48030010 Bamboo Pulp Toilet Paper Mother Roll RMHS Code: 48030010 Unbleached Bamboo Pulp 3 Ply GSM: 16g Width: 1400mm Diameter: 1150mm 1 roll in a shrink wrapped PE film 5. Bamboo Pulp Mother Roll Toilet Paper 1400mm 2 Ply 48030010 Unbleached Bamboo Pulp 2 Ply GSM: 16g Width: 280mm 6. Bamboo Pulp Mother Roll Toilet Paper 705mm 3 Ply 48030010 Unbleached Bamboo Pulp 3 Ply GSM: 16g Width: 705mm Diameter: 1150mm 150kg/roll 7 Bamboo Pulp Mother Roll Serving Napkin 2 Ply SN50 48030010 Unbleached Bamboo Pulp 3 Pl....
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....g covers two categories of goods : (1) Toilet or facial tissue stock, towel or napkin stock and similar paper of a kind used for household or sanitary purposes. However, such paper in rolls of a width not exceeding 36 cm or cut to any size or shape other than that mentioned in Note 8 to this Chapter, and other household or sanitary articles made from this kind of paper fall in heading 48.18. (2) Cellulose wadding and webs of cellulose fibres. However, such products in rolls of a width not exceeding 36 cm or cut to any size or shape other than that mentioned in Note 8 to this Chapter, and other articles of cellulose wadding or webs of cellulose fibres, fall in heading 48.18, 48.19 or 48.23. Cellulose wadding consists of a creped web of cellulose fibres of open formation, with a crepe ratio of more than 35% comprising one or more plies, with each ply having a grammage (basis weight) that may reach 20 g/m2 before creping. Webs of cellulose fibres (tissues) consist of a creped web of cellulose fibres of closed formation, with a maximum crepe ratio of 35 %, comprising one or more plies, with each ply having a grammage (basis weight) that may reach 20 ....
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.... (c) Paper and cellulose wadding impregnated, coated or covered with soap or detergent (heading 34.01), or with polishes, creams or similar preparations (heading 34.05). (d) Articles of Chapter 64. (e) Headgear and parts thereof of Chapter 65. (f) Sanitary towels (pads) and tampons, napkins (diapers) and napkin liners and similar articles of heading 96.19. 4. Port of Import and reply from Jurisdictional Commissionerate 4.1 The applicant in their CAAR-1 indicated that they intend to import the subject goods i.e. Paper Products of Bamboo Origin at the jurisdiction of office of the Pr. Commissioner of Customs, NS-I, JNCH, Nhava Sheva, Tal: Uran Distt: Raigad, Maharashtra-400707. In terms of Provisions of the Section 28-I(1) of the Customs Act, 1962 read with the Sub-regulation No. (7) of the Regulation No. 8 of the Customs Authority for Advance Rulings Regulations, 2021, the application was forwarded to the office of the Principal Commissioner of Customs, NS-I, JNCH, Nhava Sheva, Tal: Uran Distt: Raigad, Maharashtra-400707 on 09.04.2025 as indicated by the applicant at Sr. No. 13 of their CAAR-1 Forms calling upon them to furnish the relevant r....
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....ing process in paper manufacturing and cutting to tradable (required) size is expected. 7. Discussions and Findings 7.1 I have considered all the materials placed before me in respect of the classification of subject goods. I have gone through the submissions made by the applicant during the personal hearing. Therefore, I proceed to pronounce a ruling on the basis of information available on record as well as existing legal framework. 7.2 The applicant has sought advance ruling in respect of the classification of the paper products made of Bamboo Pulp. 7.3 At the outset, I find that the issue raised at the Sr. No. 08 in the CAAR-1 form is squarely covered under Section 28H(2) of the Customs Act, 1962 being a matter related to the classification of goods. I further find that the applicant is a holder of an Importer Exporter Code (IEC) and thereby, is a valid applicant under Section 28E (c) of the Customs Act, 1962 for filing application under Section 28H of the Customs Act, 1962. 7.4 The applicant is seeking an advance ruling for the classification of the paper products made of Bamboo and wooden products as listed below: Sr. No. Description of Paper Product S....
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....ue, let me deliberate on the legal framework prescribed in Customs Tariff Act, 1975, Chapter/Section notes along with HSN explanatory notes. Classification of goods in the Harmonized System of Nomenclature (HSN) is governed by the General Rules for the interpretations. Rule 1 of the General Rules for the Interpretation of the Import Tariff to the Customs Tariff Act, 1975 stipulate that for legal purposes, the classification of the import item shall be determined according to the terms of the headings and any relative Section or Chapter Notes. 7.6 I find that the product listed in table above are paper products made from bamboo pulp and used for household and sanitary purposes as seen from their names. Articles of Paper, Paper Pulp or Paper Board generally falls under Chapter 48. However, the products here under consideration are made up of Bamboo Pulp, so the first question before me to deliberate on is whether products made from Bamboo Pulp would also merit classification under Chapter 48 or otherwise. In this regard, I find that the HSN Explanatory notes while defining the Scope of the chapter 48, mentions as under: "For the purposes of headings 48.12, 48.18, 48.22 an....
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....s, I have gone through the relevant Chapter Notes and HSN Explanatory Notes to understand the difference between these headings. The Relevant Chapter Notes are as under: 3. Subject to the provisions of Note 7, headings 4801 to 4805 include paper and paperboard which have been subjected to calendering, super-calendering, glazing or similar finishing, false water-marking or surface sizing, and also paper, paperboard, cellulose wadding and webs of cellulose fibres, coloured or marbled throughout the mass by any method. Except where heading 4803 otherwise requires, these headings do not apply to paper, paperboard, which have been otherwise processed. .......... 8. Headings 4803 to 4809, apply only to paper, paperboard, cellulose wadding and webs of cellulose fibres: (a) in strips or rolls of a width exceeding 36 cm; or (b) in rectangular (including square) sheets with one side exceeding 36 cm and the other side exceeding 15 cm in the unfolded state. 7.10 The relevant HSN Explanatory Notes for Heading 4803 are as under: "48.03 - Toilet or facial tissue stock, towel or napkin stock and similar paper of a kind used for household or ....
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....the products under Heading 4803 i.e. to be able to classify under Heading 4803, the product width should be exceeding 36 cm if in strips or roll form or the products' one side should exceed 36 cm and the other side should exceed 15 cm if in the form of sheets (rectangular or square). 7.12 From the above, it appears that to be able to be classified under Heading 4803, following two conditions should be met: i. stock paper (whether or not creped, embossed, perforated or printed) as allowed by EN 4803 (not in finished form) ii. width should be exceeding 36 cm if in strips or roll form or the products' one side should exceed 36 cm and the other side should exceed 15 cm if in the form of sheets (rectangular or square). 7.13 Further, HSN Explanatory Notes makes it abundantly clear that such papers and paper products for use in household or sanitary purpose which do not meet the size criteria merits classification under Heading 4818. 7.14 The relevant HSN Explanatory Notes for Heading 4818 are as under: "48.18 - Toilet paper and similar paper, cellulose wadding or webs of cellulose fibres, of a kind used for household or sanitary purposes, in rolls....
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....oducts: i. Toilet paper and similar paper, cellulose wadding or webs of cellulose fibres, of a kind used for household or sanitary purposes, in rolls of a width not exceeding 36 cm, or cut to size or shape ii. handkerchiefs, cleansing tissues, towels, tablecloths, serviettes, bed sheets and similar household, sanitary or hospital articles, articles of apparel and clothing accessories, of paper pulp, paper, cellulose wadding or webs of cellulose fibres From the above, I find that the size restriction in only in respect of first category of products and there is no size restriction in respect of the second category product i.e. handkerchiefs, cleansing tissues, towels, tablecloths, serviettes, bed sheets and similar articles for use in household, sanitary or hospital made up of paper pulp which also includes Bamboo Pulp (as per the General HSN Explanatory Notes defining the scope of the chapter) or paper or cellulose wadding or webs of cellulose fibres would merit classification under this heading irrespective of their size. 7.16 In summary, the legal framework establishes a clear, dispositive rule based on dimensions and processing status for classification b....
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....m view cannot be made at this count. Accordingly, I refrain from passing a classification ruling for this product. 8. As far as other products are concerned, in light of the given descriptions, discussions and observations, here in above, the classification of the products, as per the submissions made by the applicant in regards to the width of the subject goods, has been arrived at as follows: Sr. No. Description of Paper Product Specification Width / Size HSN 1. Bamboo Pulp Mother Roll Serving Napkin 1 Ply for SN100 1 Ply*17- 7.5GSM, 280mm*1100mm Bamboo Pulp Unbleached Roll Dia 1100mm Core 7.6cm Pe Bags Wrapped 280mm (28cm) 48183000 2. Bamboo Pulp Mother Roll Kitchen Towel Single Use 1430 mm Unbleached Bamboo Pulp GSM:17g Diameter: 1150mm 1430mm (143cm) 48030010 3. Bamboo Pulp Mother Roll Kitchen Towel Reusable 910 mm 110 GSM 910mm Needle-punched Nonwovens Jumbo 910mm (91cm) Classification could not be decided in absence of proper literature 1 technical specification 14 4. Bamboo Pulp Mother Roll Toilet Paper 1400mm 3 Ply Bamboo Pulp Toilet Paper Mother Roll RMHS Code: 48030010 Unbleached Bamboo Pulp 3 Ply GS....