In re Kataria Traders (CAAR Mumbai)
M/s Kataria Traders filed an application before the Customs Authority for Advance Rulings (CAAR), Mumbai, seeking classification of imported “Roasted Areca Nut / Betel Nuts.” The applicant proposed classification under Customs Tariff Item (CTI) 2008 19 91 of the First Schedule to the Customs Tariff Act, 1975, read with the HSN Explanatory Notes to Heading 2008. The goods are imported from Indonesia through ports under Ahmedabad Customs jurisdiction.
The applicant detailed the mechanized roasting process involving de-husking, cleaning, drying, repeated high-temperature roasting (above 100°C, typically 130–150°C), cooling, and reduction of moisture content to 5–6%. The applicant submitted that roasting results in significant physical and chemical changes, including reduction of tannin and arecoline content. The roasted product is edible in its actual form, suitable for immediate consumption, and sold in the market as roasted betel nut or roasted supari, with FSSAI approval. The applicant argued that roasting is distinct from drying and moderate heat treatment mentioned under Chapter 8 and that roasted areca nuts are specifically covered under Heading 2008 as “other roasted nuts and seeds,” including dry-roasted areca (betel) nuts.
The applicant examined classification under Chapters 8, 20, and 21. It contended that Chapter 8 covers fresh, dried, chilled, or provisionally preserved nuts, and Note 3 to Chapter 8 allows moderate heat treatment for preservation or stabilization, but does not include roasting. Roasting, involving high heat and structural changes, is distinct from drying. The applicant relied on HSN Explanatory Notes to Heading 2008, which expressly include dry-roasted areca (betel) nuts, and cited judicial precedents and earlier advance rulings supporting classification under Chapter 20. The applicant further stated that previous CAAR rulings classifying roasted areca nuts under CTH 2008 19 20 had been upheld by the Madras High Court and affirmed by the Supreme Court. The renumbering of tariff item 2008 19 20 to 2008 19 91 under the Finance Act, 2025 was described as a technical modification without substantive change.
