AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
2026 (4) TMI 166
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.... Applicant"), hereby declare our intention to engage in the import and trade of " PS MOULDING, PS WALL PANEL, PS L PROFILE, PS WALL PANEL SHEET, PVC PANEL FOAM, PVC SHEET UV, PVC PANEL, PVC VINYL SHEET, PVC PANEL WPC MOULD, PVC WALL PANEL, PU WALL PANEL" (hereinafter referred to as "the Products") through our aforesaid company . It is anticipated that the Products will be classified under Chapter heading 3921 of the Customs Tariff Act, 1985, as amended from time to time. For the purpose of trading of the aforementioned Product, the Applicant intends to import the same from multiple countries such as China. 1.3. The Applicant seeks an advance ruling on the classification and applicable duty rates for the imported products, in accordance with the provisions set forth in the Customs Act, 1962, and related regulations. The Subject Goods constitute PS moulding/ wall panel/L profile/wall panel sheets, PVC panel/ foam/sheet/uv panel/ vinyl sheet/panel wpc mould, wall panel, PU wall panel exhibiting cellular structure, produced primarily for decorative applications in interior spaces. These products manifest the following defining characteristics: a) They are of uniform sizes a....
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....to blocks of regular geometric shape, whether or not printed or otherwise surface worked (for example, polished, embossed, coloured, merely curved or corrugated), uncut or cut into rectangles (including squares) but not further worked (even if when so cut, they become articles ready for use)." 1.7 The Subject Goods conform precisely to this statutory definition, as they: a. Constitute plates/sheets of regular geometric configuration; b. May incorporate surface treatments such as printing, embossing, colouring, or corrugation; c. Are presented either uncut or cut into rectangular/square formats without further processing; 1.8 Furthermore, heading 3921 explicitly encompasses plates, sheets, film, foil and strip of plastics that exhibit cellular structure or have undergone reinforcement, lamination, or combination with other materials. The explanatory notes to this heading unequivocally state: "plates, sheets, film, foil and strip, of plastics ... It therefore covers only cellular products or those which have been reinforced, laminated, supported or similarly combined with other materials." 1.9 The Subject Goods matches with this descriptio....
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....ics, cellular or reinforced/combined with other materials," whereas heading 3925 constitutes a residual classification limited to "builders' ware not elsewhere specified or included." 1.12. "Not Elsewhere Specified or Included" Limitation of Heading 3925 1.12.1. The phrase "not elsewhere specified or included" in heading 3925 represents a statutory recognition that goods specifically covered under alternative headings cannot be classified under heading 3925. It is apparent from The Harmonized System Explanatory Notes that residual headings with the phrase "not elsewhere specified or included" have a lower classification priority than specific headings that precisely encompass the goods in question. 1.12.2. Since the Subject Goods are specifically and comprehensively covered under heading 3921 as "sheets of plastics" with explicitly enumerated characteristics, they cannot be diverted to the residual heading 3925. The mere application of these decorative sheets to walls does not supersede their essential character as "sheets" specifically provided for under heading 3921. 1.12.3. It represents a fundamental principle of customs classification that when a product receiv....
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....ssary for any construction or "builder's ware" application. 1.14. The Subject Goods cannot function as structural elements in the following applications: a) Floors: The Subject Goods lack necessary durability, thickness, and load- bearing capacity required for flooring applications. They are neither designed for, marketed for, nor utilized on floors. b) Walls and Partitions: Classifying the subject goods wall or partition elements wrongly mixes up decorative wall coverings with actual structural wall parts. The Subject Goods are applied to preexisting walls exclusively for decorative purposes; they do not themselves create walls or partitions. Partitions cannot be constructed using the Subject Goods, as they merely constitute decorative overlays applied to structural elements already in place-functionally equivalent to paint or wallpaper. c) Ceilings and Roofs: The Subject Goods are too lightweight and lack requisite structural integrity to function as ceiling or roof elements. They may be applied to existing ceilings exclusively for decorative purposes, analogous to paint or wallpaper application. 1.15. The mere fact that a sheet/panel can be a....
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....9.21 which corresponds to Central tariff entry 3921. The explanatory note under this heading in HSN read as under: 'This heading covers plates, sheets, film, foil und strip, of plastics, other than those of heading 39.18, 39.19 or 39.20 or of Chapter 54. It therefore covers only cellular products or those which have been reinforced, laminated, supported or similarly combined with other materials. (For the classification of plates etc, combined with other materials, see the General Explanatory Note).' According to Note 10 to this Chapter, the expression "plates, sheets, foil and strip" applies only to plates, sheets, film, foil and strip and to blocks of regular geometric shape, whether or not printed or otherwise surface worked (for example, polished, embossed, coloured merely curved or corrugated), uncut or cut into rectangles (including squares) but not further worked (even if when so cut, they become articles for ready for use). The Ld. Advocate in this context has urged that reliance could not be placed on the HSN notes for interpreting Central Excise tariff entries. We observe that Hon'ble Supreme Court in the case of Wood Craft Products Ltd.1995....
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....milar matter, Ruling No. CAAR/Del/Shri Ganesh/71/2025 dated 07.10.2025 the Customs Authority for Advance Rulings has already examined the identical issue of classification of PVC Wall Panels, PS Sheets, PU Wall Panels, PVC Sheets (UV), etc., and has held that such decorative wall panels/sheets are classifiable under CTH 3921 and not under CTH 3925. The Authority, after detailed analysis of the product description, technical literature, Chapter Notes and Explanatory Notes, concluded that these goods are essentially decorative sheets/panels of plastics lacking the structural attributes required for coverage under Heading 3921. 1.21. СONCLUSION 1.21.1. Based upon comprehensive analysis of the Subject Goods' physical characteristics, relevant legal provisions, explanatory notes, and established classification principles, the Applicant respectfully submits that proper classification of "PS MOULDING, PS WALL PANEL, PS L PROFILE, PS WALL PANEL SHEET, PVC PANEL FOAM, PVC SHEET UV, PVC PANEL, PVC VINYL SHEET, PVC PANEL WPC MOULD, PVC WALL PANEL, PU WALL PANEL" falls under the appropriate subheadings of heading 3921 of the Customs Tariff Act. 1.21.2. Commercial understandi....
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....s submitted that the subject goods are plastic products exhibiting a cellular structure and are manufactured primarily for decorative applications in interior spaces. The Applicant has, inter alia, made the following claims: (a) the goods are of uniform sizes and are either ready for use or not further worked upon; (b) the goods are reinforced or combined with other materials to enhance strength or functionality; (c) the goods possess a cellular structure making them lightweight and suitable for decorative use; (d) even after cutting, the goods remain ready for use in their original form as panels or sheets; (e) the goods are primarily used for interior decoration purposes such as wall coverings and ceiling decoration to enhance the aesthetic appeal of domestic or commercial spaces; (f) the goods do not serve any structural or constructional purpose and therefore cannot be regarded as builders' ware; (g) modern decorative PVC/PU/PS panels have replaced conventional wall paints due to their aesthetic and functional advantages. 2.5. On the basis of the above submissions, the Applicant has contended that the subject....
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....enance 2.11.2. Thus, the subject goods perform both functional and architectural roles and are not merely decorative overlays or temporary coverings. 2.12. Exclusion from Headings 3920 and 3921 Chapter Note 10 "10. In headings 3920 and 3921, the expression "plates, sheets, film foil and strip" applies only to plates, sheets, film, foil and strip (other than those of Chapter 54) and to blocks of regular geometric shape, whether or not printed or otherwise surface-worked, uncut or cut into rectangles (including squares) but not further worked (even if when so cut they become articles ready for use)." 2.13. Exclusion Paras under HSN of CTH 3920 may also be referred for exclusion of the subject goods for the classification under CTH 3920 as under- "According to Note 10 to this Chapter, the expression "plates, sheets, film, foil and strip" applies only to plates, sheets, film, foil and strip and to blocks of regular geometric shape, whether or not printed or otherwise surface-worked for example, polished, embossed, coloured, merely curved or corrugated), uncut or cut into rectangles (including squares) but not further worked (even if when so cut they become ar....
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....ge contains a corresponding groove. During installation, the tongue of one panel fits into the groove of the adjacent panel, forming a continuous and stable surface. (b) Click-lock system: In this system, precision-engineered edge profiles snap together mechanically, creating a firm and integrated joint without the need for additional fasteners. 2.18.2. Mechanism: The edge profiles are precision-engineered to engage and lock with a simple push, creating a secure mechanical fit Click-lock systems are very easy and fast to install providing a strong, integrated joint. 2.18.3 Such engineered interlocking systems represent specialised shaping and further working well beyond simple cutting or surface working. These features are essential for permanent installation and continuous alignment of the panels. 2.19. Applicability of Heading 3925-Builders' Ware of Plastics 2.19.1 The HSN Explanatory Notes to Heading 3925 clarify that the heading covers, inter alia * structural elements used in floors, walls or partitions, ceilings or roots and * ornamental architectural features, such as flutings 2.19.2. The subject goods are design A Preparation wa....
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....herefore, in terms of Chapter 39 Note 11(B), HSN and established principles of classification, the subject PVC panels merit classification as builders' ware of plastics under Heading 3925 2.21. Ornamental Architectural Features - Chapter Note 11(h) 2.21.1. Chapter Note 11(h) to Chapter 39 expressly provides that Heading 3925 includes "ornamental architectural features, for example, flutings, cupolas, dovecotes." The said Chapter Note thus clarifies that the scope of Heading 3925 encompasses decorative architectural elements added to a building or structure with the objective of enhancing its aesthetic and architectural character. The specific reference to flutings as an illustrative example reinforces the legislative intent to cover profiled and ornamented architectural components, particularly those forming part of walls or ceilings. 2.21.2. In architectural and trade parlance, PVC panels and allied products are manufactured with embossed designs, three-dimensional textures, flutings and louvers, which enhance the architectural finish of walls and ceilings. When designed for and used in permanent installation, such products constitute ornamental architectural features....
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....neered interlocking systems, permanent installation, and the statutory provisions and explanatory notes of Chapter 39, it is evident that the subject goods possess the essential character of structural elements and ornamental architectural features. 2.23.2. Accordingly, the subject goods are appropriately classifiable under CTH 3925, specifically CTH 392590 (Other builders' ware of plastics), and do not merit classification under CTH 3920 or 3921 as claimed by the Applicant. 3. Record of Personal hearing: The authorized representative of the applicant participated in the personal hearing conducted through virtual mode on 12.02.2026 and reiterated the submissions as set forth in the application. He submitted that the response to the port comments had already been filed via email and requested that the same be taken on record. The authorized representative further prayed that the matter be decided on merits. No one attended the PH on behalf of the Department. 4. Additional Submission of the Applicant: 4.1. Before addressing the department's contentions paragraph-wise, it is imperative to highlight that our application extensively relies upon three critical lega....
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....irectly on point remain unrebutted, the department's case stands demolished at the threshold itself. Having established this foundational legal position, we now wish to proceed to address the department's contentions paragraph-wise. 4.3. It is most respectfully submitted that the claims advanced by the applicant are duly supported with the technical characteristics of the goods as well as applicable judicial precedents and statutory provisions The detailed response in respect to the Departments contentions is provided as under: 4.4. The department has made elaborate assertions regarding the manufacturing process, claiming that PVC wall panels undergo "a series of operations including extrusion, formation of hollow or cellular core structures, edge profiling, milling and shaping to create interlocking joints, surface embossing, texturing, lamination, UV coating or decorative finishing" and that "post-extrusion processes further include precision cutting and joint refinement, resulting in non-rectangular, interlocking forms." These assertions are fundamentally flawed and not based on any technical evidence or expert opinion specific to our products. The department appea....
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....xtrusion die design and are formed during the extrusion process itself. There is no separate post-extrusion surface treatment operation. UV coating, where applied, is a surface treatment akin to painting and does not alter the essential character of the product as a plastic sheet. 4.5. The department's characterization of these products as "three-dimensional, profiled construction elements" is a gross exaggeration. The products remain essentially flat rectangular sheets with surface texturing for decorative appeal. The presence of surface patterns does not transform a sheet into a "construction element." The department has provided no technical evidence, expert opinion, or manufacturer's literature to support their elaborate description of the manufacturing process. Their assertions appear to be based on speculation and a fundamental misunderstanding of PVC extrusion technology. 4.6. The department has claimed that the subject goods "provide surface protection, insulation against heat and sound, resistance to moisture and impact, and durability and ease of maintenance" and therefore "perform both functional and architectural roles and are not merely decorative overlay....
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....the products. 4.8. The photographs attached with our application clearly demonstrate that the products feature decorative patterns, textures, and designs (such as stone effects, wood grain effects, fluted patterns, 3D designs) that serve purely aesthetic purposes. These are not the characteristics of construction materials but of decorative wall coverings. The department's attempt to elevate incidental material properties into the "essential character" of the products is contrary to established principles of tariff classification and contradicts the commercial understanding of these products. 4.9. The department has relied heavily on Chapter Note 10 to Chapter 39 to exclude our products from Headings 3920 and 3921. This reliance is fundamentally misplaced. Para 7 of the departmental comments reproduces Chapter Note 10 and the relevant HSN Explanatory Notes and concludes that our products are excluded because they are "profiled and shaped, have engineered interlocking edges, possess three- dimensional decorative contours, are cut into non-rectangular forms, and undergo extensive post-extrusion working beyond mere surface treatment." This conclusion is erroneous for reason ....
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....14. The department has quoted the HSN Explanatory Notes stating that plates and sheets "with ground edges, drilled, milled, hemmed, twisted, framed or otherwise worked or cut into shapes other than rectangular (including square) are generally classified as articles of headings 39.18, 39.19 or 39.22 to 39.26." Our products have none of these features. The presence of an interlocking edge profile that is part of the original extrusion does not constitute "milling" or "working" within the meaning of this exclusion. The Tribunal in Bakelite Hylam held that plastic tiles in square and rectangular shapes are classifiable under Heading 3921 even when they possess cellular structure and are reinforced. The department has not explained how our products, which are also cellular plastic sheets in rectangular form, should be treated differently. 4.15. The department's interpretation of Note 10 is unduly restrictive and would result in virtually all cellular or textured plastic sheets being excluded from Headings 3920/3921, contrary to the clear scope of these headings and their Explanatory Notes. Departmental comments provides detailed descriptions and diagrams of tongue-and-groove and ....
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....ally flawed and demonstrates a misunderstanding of both the nature of our products and the scope of Heading 3925. 4.17. Heading 3925 is titled "Builders' ware of plastics, not elsewhere specified or included." The critical phrase is "not elsewhere specified or included." This is a residual heading that applies only when the goods in question are not covered by any other, more specific heading within Chapter 39. The HSN Explanatory Notes to Heading 3925 begin with the statement "Heading 3925 applies only to the following articles, not being products covered by any of the earlier heading of sub-Chapter II" and this is followed by an exhaustive list of nine categories from (a) through (ij), namely: reservoirs, tanks and similar containers of capacity exceeding 300 liters; structural elements used in floors, walls or partitions, ceilings or roofs; gutters and fittings thereof; doors, windows and their frames and thresholds; balconies, balustrades, fencing, gates and similar barriers; shutters, blinds and similar articles; large-scale shelving for permanent installation; ornamental architectural features such as flutings, cupolas, dovecotes; and fittings and mountings for permane....
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....ctural elements used in walls" any more than paint is a structural element. If the department's interpretation were correct, then paint, which provides surface protection, moisture resistance, and is installed on walls, should also be classified as "builder's ware." In construction and architectural terminology, our products are universally understood as "wall coverings" or "decorative panels," not as "structural elements." The mere fact that a product is used on walls does not make it a "structural element used in walls." The category contemplates products that are integral to the wall structure itself, not decorative overlays applied to finished walls. iii. Gutters and fittings thereof constitute the third category. Our products are flat panels used for interior wall decoration and have no connection whatsoever to gutters or drainage systems. This category is entirely inapplicable. iv. The fourth category covers doors, windows and their frames and thresholds for doors. Our products are not doors, windows, frames, or thresholds. They are not used for access, ventilation, or as part of openings in walls. This category is entirely inapplicable. v. ....
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....pes with decorative surface patterns applied to walls.' Moreover, the availability of any drawings to prove the architectural characteristic of subject goods is imperative, which is absent in this case .The department has attempted to classify products with simple embossed or textured surfaces as "ornamental architectural features" comparable to flutings, cupolas, and dovecotes. This is a fundamental mischaracterization. If this interpretation were accepted, then any decorative item applied to walls, including embossed wallpaper, decorative tiles, or even textured paint, would become "ornamental architectural features" under this category. This cannot be the legislative intent. Moreover, the department itself acknowledges in Para 9B.2 that these products are used for "interior decoration purposes" and to "enhance the aesthetic appeal of domestic or commercial spaces," which is precisely the function of decorative wall coverings. not architectural features. ix. The ninth category relates to fittings and mountings intended for permanent installation in or on doors, windows, staircases, walls or other parts of buildings. The examples given are hardware items such as knobs....
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....;s. The products are marketed as "decorative wall panels" or "interior decorative solutions," not as "construction materials" or "builders' ware." The fact that they are sold through channels that also sell other interior products such as paints, wallpapers, floorings, and furnishings does not transform them into builders' ware. 4.20.4. The department's emphasis on "permanent installation" in Para 9A.4 is factually incorrect. As demonstrated through the photographs in our application, the panels are attached using adhesive or small screws and can be removed without damaging the underlying wall. This is fundamentally different from construction elements like drywall or partition systems, which are integrated into the building structure and cannot be removed without significant damage. The department's test of "permanency" would classify even wallpaper as "builders' ware" since wallpaper, once pasted, is not ordinarily removed without damage to itself. This demonstrates the flawed nature of the department's reasoning. 4.20.5. Most critically, Chapter Note 11(B) applies to "builders' ware not elsewhere specified or included." Even if our products coul....
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....esthetic enhancement of interior spaces through finishes, furnishings, colors, and textures. It is about creating visual appeal within completed spaces. Architectural features, on the other hand, are structural or design elements that are integral to the architectural design and structure of the building itself, such as columns, arches, domes, cupolas, pediments, and similar elements which can be manufactured on the basis of a drawing made by architect to finally take a shape of domes or cupolas. Our products serve interior decoration purposes as decorative finishes applied to walls, not as architectural features that form part of the building's architectural design. 4.21.3. If the department's interpretation were correct, then embossed or textured wallpaper would also be "ornamental architectural features" since it too has decorative patterns and is used to enhance aesthetic appeal of walls. This is clearly an incorrect interpretation. The legislative intent in including "ornamental architectural features" in Heading 3925 was to cover specialized architectural elements made of plastic, such as plastic replicas of classical architectural details including columns with fl....
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....ere to evade duty, we would have simply changed the classification in our Bills of Entry and imported the goods. Instead, we have proactively sought advance ruling, which is the very purpose for which this mechanism has been created. (f) The department's suggestion that our approach is motivated by duty rate considerations is both factually incorrect and legally irrelevant. Classification must be determined based on the nature and characteristics of the goods and the applicable statutory provisions, not on the basis of duty rates. 5. Discussion, Findings & Conclusion: 5.1 Having examined the CAAR-1 application, the comments received from the jurisdictional Customs Commissionerate, the record of personal hearing held on 12.02.2026, additional written response of the applicant and the applicable legal framework, I find the application to be valid in terms of the Customs Act, 1962 and the CAAR Regulations, 2021. I, therefore, allow the application and proceed to determine the classification of the proposed imports on the basis of the information on record. Product description: 5.2 The question before me in this case relates to the classification of the goods p....
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....the First Schedule to the Customs Tariff Act, 1975, reads as under: 3921 OTHER PLATES, SHEETS, FILM, FOIL AND STRIP, OF PLASTICS - Cellular: 3921 11 00 -- Of polymers of styrene 3921 12 00 -- Of polymers of vinyl chloride 3921 13 -- Of polyurethanes: 3921 13 10 --- Flexible 3921 13 90 --- Other 3921 14 00 -- Of regenerated cellulose 3921 19 00 -- Of other plastics 3921 90 - Other: 3921 90 10 --- Thermocol --- Of polymers of vinyl chloride: 3921 90 21 ---- Rigid, lacquered 3921 90 22 ---- Flexible, lacquered 3921 90 23 ---- Rigid, metallised 3921 90 24 ---- Flexible, metallised 3921 90 25 ---- Rigid, laminated 3921 90 26 ---- Flexible, laminated 3921 90 29 ---- Other ---- Of regenerated cellulose: 3921 90 31 ---- Rigid, lacquered 3921 90 32 ---- Flexible, lacquered 3921 90 33 ---- Rigid, metallised 3921 90 34 ---- Flexible, metallised 3921 90 35 ---- Rigid, laminated 3921 90 36 ---- Flexible, laminated 3921 90 39 ....
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....efrom), with ground edges, drilled, milled, hemmed, twisted, framed or otherwise worked or cut into shapes other than rectangular (including square) are generally classified as articles of headings 39.18, 39.19 or 39.22 to 39.26." 5.5.3. The explanatory note to Tariff Heading 3925 are reproduced below: 3925 Builders' ware of plastics, not elsewhere specified or included 3925.10 - Reservoirs, tanks, vats and similar containers, of a capacity exceeding 300 1 3925.20 - Doors, windows and their frames and thresholds for doors 3925.30 - Shutters, blinds (including Venetian blinds) and similar articles and parts thereof 3925.90 - Other This heading applies only to the articles mentioned in Note 11 to this Chapter. 5.5.4. The chapter notes to Tariff Heading 3925 is reproduced below :- (11) "Heading 3925 applies only to the following articles, not being products covered by any of the earlier heading of sub-Chapter II: (a) Reservoirs, tanks (including septic tanks), vats and similar containers, of a capacity exceeding 3001; (b) Structural elements used, for example, in floors, walls or partitions, ceilings ....
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....ng, milling and shaping to create interlocking joints; surface embossing, texturing, lamination, UV coating or decorative finishing to achieve architectural aesthetics. Thus, the engineered interlocking system of PVC wall panels, formed through extrusion followed by specialized shaping and further working beyond surface-working distinguishes them from basic rectangular cuts of a flat sheet, which appear to place them outside the scope of CTH 3921, (iii) the heading 3925 covers structural elements used in floor, walls or partitions, ceilings or roofs. PVC wall panels designed for permanent installation as structural/functional and decorative coverings, providing protection, insulation, and moisture resistance, appears to qualify as such structural elements in terms of Note 11(b) of Chapter 39. The subject goods are designed for permanent installation on walls and ceilings and function as integrated architectural components. Their design, profile, method of installation and end- use clearly align with the description of structural elements under Heading 3925, (iv) Chapter Note 11(h) to Chapter 39 expressly provides that Heading 3925 includes "ornamental architectura....
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....rative wall coverings, (ii) these panels fundamentally maintain their essential rectangular geometric shape throughout the manufacturing and installation process, with the geometric integrity preserved regardless of size variations required for specific applications. When installation demands necessitate dimensional adjustments, sheets are simply cut along straight lines to produce smaller rectangular panels that accommodate particular wall dimensions, without any alteration to their basic geometric character or structural properties, particularly in the case of last panel, where full penal cannot be fit. The cutting process involves no complex shaping or specialized working beyond standard dimensional reduction, ensuring that the essential rectangular nature remains unchanged, (iii) the interlocking edges incorporated into certain panel varieties serve exclusively aesthetic purposes, specifically designed to create groove appearances that enhance visual appeal and ensure seamless visual continuity between adjacent panels during installation and too minimize the usage of small mini size screws. The departmental understanding that PVC wall panels are engineered pro....
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....minology, are components that bear loads, provide stability, or form part of the load-bearing framework of a building. Upon examining the samples of the subject goods produced before me, I find that the panels are lightweight cellular plastic sheets unable to bear any significant load. Thus, as per my understanding, the panels are not integrated into the structural framework of the building but are applied as a decorative overlay on existing finished walls. The wall structure exists independently and functions identically whether these panels are present or absent. This is fundamentally different from true structural elements like drywall, which forms the actual wall surface, or partition systems, which create the spatial divisions. The mere fact that a product is used on walls does not make it a "structural element used in walls." The category contemplates products that are integral to the wall structure itself, not decorative overlays applied to finished walls. I find these PVC panels remain essentially decorative sheets designed for aesthetic wall covering as a substitute of paint & wall papers, temporarily in nature and easily removable, lacking structural function, architectur....
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....etain the essential form of plates/sheets of plastics within the meaning of Note 10 to Chapter 39. The longitudinal interlocking/tongue-and-groove at the edges is an in-line extrusion profile and, on these facts, does not amount to "further working" of the type exemplified in the Chapter and explanatory notes (e.g., drilling, milling, framing, twisting, cutting into non-rectangular shapes). The HSN EN to 3921 explicitly embraces cellular and reinforced/laminated/supported sheet products that remain plates/sheets and are not covered by 3918/3919/3920 or Chapter 54. The subject panels fit that description. 6. In view of above discussion and findings, I hold that the goods mentioned in application are classifiable under heading 3921 of the Customs Tariff; goods of polymers of styrene in the sheet/panel form fall under 39211100; goods of polymers of vinyl chloride in the sheet/panel form fall under 39211200; goods of polyurethanes in the sheet/panel form fall under 39211390; subject to verification of the actual composition, structure (cellular/non-cellular; reinforced/laminated/supported) by the field formation in this regard. 7. I, rule accordingly. ============= Document 1....