In re ADM Agro Industries India Private Limited (CAAR Delhi)
The Customs Authority for Advance Rulings (CAAR), Delhi, examined the classification of the imported product “B-Traxim 2C Mn-220” under the Customs Tariff Act, 1975. The applicant sought an advance ruling contending that the product should be classified under Tariff Item 29224990 as a chemically defined organo-metallic compound and an oxygen-function amino compound falling under Chapter 29. The product was described as a highly concentrated organic trace mineral bound to glycine, manufactured through Iso-Fusion Technology (IFT), having a pure crystalline form, no carriers, full water solubility, homogeneous particle size, and intended for use as a nutritional additive in animal feed. According to the applicant, the product consisted of glycine, manganese, and sulfate in a crystalline polymer structure and qualified as a chemically defined compound classifiable under Heading 2922.
The applicant argued that the product’s chemical structure contained amino-acid and salt characteristics that brought it within the scope of Chapter 29. Relying on Rule 1 of the General Rules for Interpretation (GRI), Chapter Note 3 to Chapter 29, and the HSN Explanatory Notes, the applicant submitted that the product was a chemically defined organo-metallic compound formed through complexation bonds between glycine and manganese. It contended that the product’s composition corresponded to oxygen-function amino compounds and amino-acid salts covered by Heading 2922 and therefore merited classification under Tariff Item 29224990.
