In re SGS Packaging Private Limited (GST AAR Rajasthan)
The applicant, M/s SGS Packaging Private Limited, Jaipur, engaged in the manufacture and supply of paper bags for packaging purposes, sought an advance ruling under Section 97(2) of the GST Act regarding the applicable GST rate on its products. The question was whether “paper bags” classifiable under Heading 4819 of the Customs Tariff Act, 1975, would attract GST at 5% under Entry No. 319 of Schedule I to Notification No. 09/2025—Central Tax (Rate) dated 22.09.2025, or at 18% under Entry No. 185 of Schedule II of the same notification.
The applicant submitted that its products fall under Chapter 48, Heading 4819, which covers cartons, boxes, cases, bags and other packing containers of paper or paperboard. It highlighted that Entry 319 of Schedule I prescribes 5% GST on “Paper Sacks/Bags and bio-degradable bags” under Chapters 39 and 48. It also referred to the 56th GST Council meeting press release recommending reduction of GST on paper sacks/bags and bio-degradable bags from 18% to 5% with effect from 22 September 2025. However, the applicant stated in its interpretation that its products fall under Entry 185 of Schedule II and are taxable at 18%.
The jurisdictional officer examined relevant entries in Notification No. 09/2025-CT (Rate). Entry 319 of Schedule I (5%) covers “Paper Sacks/Bags and bio-degradable bags” under Chapters 39 and 48. Entry 322 of Schedule I (5%) applies to cartons, boxes and cases of corrugated or non-corrugated paperboard under subheadings 4819 10 and 4819 20. Entry 185 of Schedule II (18%) applies to “All goods” under Heading 4819 except those under subheadings 4819 10 and 4819 20.
