TaxTMI 
TaxTMI 
2026 (3) TMI 1540
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....ries are situated at Plot No. E-2, Industrial Area, Gooty Road, Guntakal, Andhra Pradesh- 515 803. The applicant is a manufacturer of water pipes, P.V.C. conduits and fittings under the brand name "VASAVI PVC PIPES". The applicant is registered with the Directorate General of Foreign Trade vide Importer-Exporter Code- 0903006065 and further registered under the GST Act vide GSTN 37AABHG0866K1Z5 w.e.f. 01.07.2025. 2.2 The applicant is planning to import "High Speed Pvc Four Pipe Extrusion Line With Accessories" from Xingang, China to their place of business in India. As submitted supra, the applicant is in the business of manufacture of PVC pipes which are commonly used for manufacturing sewage pipes, water mains and irrigation. PVC pipes are easy to install, lightweight, strong, durable and easily recyclable, making them cost-efficient and sustainable. The smooth surface of PVC pipes also encourages faster water flow due to lower amounts of friction than piping made from other materials such as cast iron or concrete. PVC pipes can also be manufactured to varying lengths, wall thicknesses and diameters, according to international sizing standards such as DIN 8061, ASTM D1785 and ....
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....ICLES NOTES: ................................. ................................. 3. Unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole and other machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function. 4. Where a machine (including a combination of machines) consists of individual components (whether separate or interconnected by piping, by transmission devices, by electric cables or by other devices) intended to contribute together to a clearly defined function covered by one of the headings in Chapter 84 or Chapter 85, then the whole falls to be classified in the heading appropriate to that function. .................. .................. The relevant tariff entries of CTH 8477 is produced as below: 8477 MACHINERY FOR WORKING RUBBER OR PLASTICS OR FOR THE MANUFACTURE OF PRODUCTS FROM THESE MATERIALS, NOT SPECIFIED OR INCLUDED ELSEWHERE IN THIS CHAPTER 84....
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....early defined single function - extrusion of plastic into pipes. Therefore, the entire system must be classified under the heading appropriate to that function, i.e., 8477. Chapter 84 - Note 2 (Heading Preference Rule): 4.5.3 There is no conflict with headings 8401-8424, as extrusion machinery is not described therein. Therefore, heading 8477 prevails, and no reclassification is warranted under competing headings. Section XVI - Note 1 (Exclusions): 4.5.6 The extruder and its components do not fall within any excluded categories listed in Note 1, such as textile machinery, ceramic appliances, or products of other specific chapters. General Interpretative Rule 1: 4.5.7 Classification is guided first by the text of the headings and legal notes. Since Heading 8477 clearly covers machinery for working plastic, and subheading 8477 20 00 specifically includes extruders, this heading most accurately reflects the nature of the goods. 4.6 Principal Function and Commercial Understanding 4.6.1 The equipment is designed and marketed as an extrusion line in the trade and technical literature. It is not intended for use in isolation or for any alternate purpose. 4.6.2 W....
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....astics. In support of the above, the applicant is also attaching a copy of the brochure received from the manufacturer. 4.6.6 Based on the above facts and the relevant legal provisions under the Customs Tariff Act, 1975, read with the Harmonized System of Nomenclature (HSN), the applicant submits that the proposed import of "High-Speed PVC Four Pipe Extrusion Line with Accessories" is correctly classifiable under HS Code 8477 20 00. 5. Port of Import and reply from jurisdictional Commissionerate: The applicant in their CAAR-1 indicated that they intend to import the subject goods from jurisdictional Commissionerate of the Principal Commissioner of Customs, Chennai Customs House, 60, Rajaji Salai, Chennai 600001. The application was forwarded to the jurisdictional of Commissionerate of the Principal Commissioner of Customs, Chennai Customs House for their comments on 07.11.2025, 22.12.2025, 09.01.2026. The said jurisdictional Commissionerate vide letter dated 19.02.2026 submitted their comments in the said matter. 6. Comments from jurisdictional Commissionerate: Vide letter dated 19.02.2026 jurisdictional Commissionerate submitted comments as below: 6.1 No case is pen....
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..... The only caveat raised is that any deviation in the actual imported machine that enables a noncontinuous moulding process, i.e., injection moulding, would invalidate the classification under CTH 84772000. In this regard, the applicant emphatically reiterates and confirms that the machine proposed to be imported is a continuous pipe extrusion line and not an injection moulding machine. As has been clearly stated in the original application, the proposed import is a "High-Speed PVC Four Pipe Extrusion Line with Accessories", which operates on the principle of continuous extrusion of molten PVC through a die to form pipes. The machine does not possess any clamping unit, clamping force mechanism, or mould cavity - all of which are defining characteristics of an injection moulding machine classifiable under CTH 84771000. The manufacturer's brochure filed with the application clearly describes and depicts the LS-PVC Four Pipe Production Line (page 1 of the brochure) comprising of a conical twin-screw extruder, pipe head, vacuum tank, haul-off and cutting unit, all components that are integral to a continuous extrusion process and not to an injection moulding process. Accordingly....
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....more, the question before this Hon'ble Authority is the classification of a "plastic extruder machine", whether it is PVC, UPVC or CPVC, the tariff classification under CTSH 8477 2000 (Extruders) remains the same, as the Customs Tariff does not draw any distinction between extruders based on the specific polymer variant they are designed to process' The relevant tariff description "Extruders" under CTH 8477 20 00 is broad enough to cover extrusion machines for all types of plastics including PVC, UPVC and CPVC. 7.2.2 Re: Comprehensive list of accessories: As already stated in the original application at paragraph 4, the proposed import is a complete extrusion line comprising the following integrated components: (a) Conical twin-screw extruder with screw and barrel; (b) Die-head system for four-pipe output; (c) Vacuum calibration and cooling tanks; (d) Haul-off unit (traction); (e) Cutter/cutting unit; (f) Electrical control panels; and (g) Online socketing/packing accessories. These are not standalone machines operating independently but are integral parts of a single, continuous pipe extrusion producti....
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.... to the express mandate of Note 4 and would also be contrary to Note 3 to Section XVI which requires composite machines to be classified based on the principal function. The applicant also enclosed a brochure of the products manufactured by M/s. Liansu Machinery downloaded from https: / /www.ls-extrusion.com/ which establishes that they manufacture only extrusion machinery and do not have any injection moulding press in their products. In view of the above, the applicant submitted that the comments of the jurisdictional Customs authority, while confirming the classification under CTSH 8477 2000, do not raise any substantive objection to the applicant's classification. 8. Details of Hearing The Personal Hearing in the said matter was held on 19.02.2026 at 01:15 PM. Shri Makarandh, Advocate appeared for PH in the matter. He reiterated the contention filed with the application that the subject import goods are extrusion machine with accessories to manufacture rigid PUC and CPVC pipes. That the whole and complete machinery is to be imported is a single consignment, and merit classification under CTH-84772000. He has relied upon the technical specification of the product....
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.... devices) intended to contribute together to a clearly defined function covered by one of the headings in Chapter 84 or Chapter 85, then the whole falls to be classified in the heading appropriate to that function." (iii) Heading 8477 Covers: "Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere." The relevant tariff entries of CTH 8477 are produced as below: 8477 MACHINERY FOR WORKING RUBBER OR PLASTICS OR FOR THE MANUFACTURE OF PRODUCTS FROM THESE MATERIALS, NOT SPECIFIED OR INCLUDED ELSEWHERE IN THIS CHAPTER 8477 10 00 - Injection-moulding machines u 8477 20 00 - Extruders u 8477 30 00 - Blow moulding machines u 8477 40 00 - Vacuum moulding machines and other thermoforming machines u - Other machinery for moulding or otherwise forming: 8477 51 00 -- For moulding or retreading pneumatic tyres or for moulding or otherwise forming inner tubes u 8477 59 00 -- Other u 8477 80 - Other machinery : 8477 80 10 --- Machinery for maki....
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....ines, on the other hand, operate on a fundamentally different principle involving the injection of molten material into a closed mould under pressure, coupled with a clamping mechanism to hold the mould halves together during the process. These defining characteristics are conspicuously absent in the present case. 9.12 I further observe that the distinction between extrusion and injection moulding is clear, well- established, and technically evident, as also demonstrated by the comparative analysis and diagrammatic representations furnished by the applicant (refer para 4.6 above). The same reinforces that the subject goods function exclusively as extrusion machinery. 9.13 In view of the above, the subject goods cannot be classified under sub-heading 8477 10 00 and are appropriately classifiable under sub-heading 8477 20 00 (Extruders). Composite Machine and Functional Unit Analysis 9.12 The subject goods comprise a combination of multiple interconnected components, such as the extruder, die-head, vacuum calibration and cooling tanks, haul-off unit, cutter, and control systems, which are designed to operate together as a single integrated system. Accordingly, the applica....
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....e has, however, raised a concern that certain downstream equipment may be capable of independent classification under separate tariff headings. 9.22 This issue is required to be examined in light of Note 4 to Section XVI, which embodies the principle of classification of functional units. 9.23 It is a well-settled position that where: * Goods are imported together as a complete system; * Such goods are interconnected and integrated; and * They collectively perform a single, clearly defined function, the entire assembly is to be classified as a functional unit under the heading appropriate to that function, notwithstanding that individual components may, if presented separately, fall under different headings. 9.24 At the same time, it is equally settled that this principle applies only in cases where the constituent components do not possess independent and standalone functionality in the given configuration. 9.25 In the present case, based on the detailed submissions of the applicant and the technical literature on record, it is observed that: i) The claimed accessories, including calibration tanks, haul-off units, cutters and cont....