AAR Tamil Nadu Denies 5% GST as Compostable Bags Are Not Biodegradable

In re Symphony Polymers Private Limted (GST AAR Tamilnadu)

M/s Symphony Polymers Private Limited, engaged in manufacturing and supplying compostable bags, packing materials, biodegradable bags and recycled products, sought an advance ruling under Section 97 of the CGST Act, 2017 and corresponding TNGST provisions. Its compostable bags were made from Poly Lactic Acid (PLA) and Poly Butylene Adipate Terephthalate (PBAT), tested by CIPET under IS/ISO 17088 and certified by the Central Pollution Control Board (CPCB) for manufacture of compostable carry bags. The applicant stated that, from 22.09.2025, Notification No. 9/2025-CT(R) dated 17.09.2025 reduced GST to 5% for specified paper sacks/bags and bio-degradable bags under Entry 319 of Schedule I, and sought a ruling on classification and eligibility for the concessional rate.

The applicant argued that compostable plastics constituted a specialised subset of biodegradable plastics, that its products satisfied IS/ISO 17088 standards, and that its certification and biodegradability supported classification as biodegradable bags eligible for the 5% rate. During the personal hearing on 06.07.2026, the authorised representative also relied on a Ministry of Environment, Forest and Climate Change press release dated 23.03.2026 concerning GST rationalisation and green transition. Further submissions dated 13.07.2026 stated that the applicant’s PLA-PBAT products were starch-based and covered by the rationale described in the press release. Physical samples were also produced before the Authority.

The Authority found the application admissible under Section 97(2)(a) and (b), concerning classification and applicability of notifications. On classification, the CIPET test report identified the sample as a blend of PLA and PBAT. The Authority therefore held that the compostable bags were made from plastic/polymer materials rather than paper and were classifiable under Chapter 39, specifically HSN 3923 2990 – Articles for the conveyance or packing of goods, of other plastics – sacks and bags (including cones).

On the concessional GST rate, the Authority noted that Entry 319 of Schedule I to Notification No. 9/2025-CT(R) provides a 5% rate for paper sacks/bags and bio-degradable bags under Chapters 39 and 48, subject to the goods being biodegradable. Since “biodegradable” was not defined under GST law, the Authority relied on the Plastic Waste Management Rules, 2016, as amended. Rule 10 required biodegradable plastics to conform to the applicable Bureau of Indian Standards certification framework, including tentative IS 17899 T:2022, while compostable plastics conform to IS/ISO 17088:2021.

The Authority observed that IS 17899 T:2022 specifically excludes compostable plastics assessed under IS/ISO 17088 from its scope. Although the applicant possessed CIPET testing and CPCB certification for compostable carry bags conforming to IS/ISO 17088, it had not produced documentary evidence or valid CPCB certification for manufacturing biodegradable carry bags/commodities conforming to IS 17899 T:2022. Consequently, the Authority held that the applicant’s compostable bags did not fall within the category of “bio-degradable bags” covered by Entry 319.

The Authority further held that the applicant’s additional submissions concerning the March 2026 press release and PLA/PBAT composition were inconsequential because the requisite statutory compliance for classification as biodegradable products had not been established. Accordingly, the Authority ruled that the bags were classifiable under HSN 3923 2990 but their supplies were not covered by Entry 319 of Schedule I to Notification No. 9/2025-CT(R) and were therefore not eligible for the stated 5% GST rate.

FULL TEXT OF ORDER OF AUTHORITY OF ADVANCE RULING TAMILNADU

M/s Symphony Polymers Private Limited, having place of business at Plot No. 18, SIDCO Industrial Estate, Manali New Town, Chennai 600103, Tamil Nadu (hereinafter called as the Applicant’) is registered under the Goods and Service Tax Act, with GSTIN 33AAICS0641Q1Z3. They have filed an application for Advance Ruling under Sec.97 of the CGST Act, 2017 and the corresponding provision of the TNGST Act, 2017. The Applicant has made the payment of Rs.10,000/- towards application fees, under sub rule (1) of Rule 104 of CGST Rules, 2017 and TNGST Rules, 2017.

2. Statement of relevant facts having a bearing on the questions raised.

The Applicant states that they are engaged in the business of manufacturing and supply of compostable bags and packing materials, biodegradable bags and packing materials and recycled products. They state that the compostable bags and packing materials manufactured by them are tested by CIPET- Institute of Plastics Technology, under the IS 17088 standards and have been certified as biodegradable vide their certificate No.59002 dated 23.10.2019. These products are stated to be manufactured using biodegradable polymer blends such as Poly Lactic Acid (PLA) 86 Poly Butylene Adipate Terephthalate (PBAT), which are essentially designed to biodegrade into organic matter, water and CO2 without toxic residue. They have further stated that the CPCB, New Delhi, has issued them a certificate in No.B-17011/7/PWM(COMP)/2021(SPPL) dated 02.03.2021, certifying that they have fulfilled the criteria as per the revised SOP, to manufacture compostable carry bags.

The Applicant state that their products are at present, classified under Chapter heading 3923 – Articles for the conveyance or packing of goods, of plastics ; that, however, wef 22.09.2025, the GST rate on ‘Chapter 39/48 – specified paper sacks/ bags and Bio-degradable bags’ has been reduced to 5%, vide Notification 9/2025-CT (R) dated 17.09.2025. In this context, the applicant seek to know whether the compostable bags and packing materials that are certified to be bio­degradable, should be classified under chapter 39, attracting a concessional rate of 5% or under CSH 3923 attracting 18% GST.

3. The applicant has therefore, sought an Advance Ruling, under Sec.97(2)(a) and (b) of the CGST Act, 2017, on the following questions:

1. Classification/HSN: Whether the applicant’s compostable bags and packing materials are classifiable under Chapter 39 (if, of plastic/compostable polymer) or Chapter 48 (if of paper) and the appropriate HSN;

2. Rate of tax & applicability of Notification — Whether supplies of the said compostable bags and packing materials are covered by the entry Paper sacks/Bags and bio-degradable bags’ (Ch 39, 48) in Schedule I of Notification 9/2025-CTR, attracting 5% GST wef 22.09.2025?

4. Applicant’s interpretation of law:

The Applicant ^–s interpretation of the above classification is based on the following:

A. Definition of Biodegradable plastics Vs. Compostable Plastics :

(As provided under Rule 3 of the Plastic Waste Management Rules, 2016, as amended by Plastic Waste Management (Second Amendment) Rules, 2022, issued by the Ministry of Environment, Forest and Climate Change)

(ac) “Biodegradable plastics” means plastics, other than compostable plastics, which undergoes degradation by biological processes under ambient environment (terrestrial or in water) conditions, without leaving any micro plastics, or visible, or distinguishable or toxic residue, which has adverse environment impacts, adhering to laid down standards of Bureau of Indian Standards and certified by the Central Pollution Control Board;

(e) “compostable plastics” mean plastic that undergoes degradation by biological processes during composting to yield CO2, water, inorganic compounds and biomass at a rate consistent with other known compostable materials, excluding conventional petro-based plastics, and does not leave visible, distinguishable or toxic residue;

B. That, as per the above definitions,

• • • both ‘Biodegradable plastics’ and Compostable plastics’ degrade through biological processes without leaving any harmful residue;
    • the only distinction is the environmental conditions under which such degradation occurs;
    • While ‘Compostable plastics’ degrade under a controlled composting environment, ‘Biodegradable plastics’ degrade under ambient environmental conditions such as soil or water.

C. As per the specification of ‘Compostable Plastics’ – IS/ISO 17088, issued by Bureau of Indian Standards, ‘Compostable plastics’ should

• • • undergo biodegradation;
    • convert into CO2, water and biomass;
    • leave no toxic residue.

D. Further, as per the Central Pollution Control Bureau Certification Framework, ‘Compostable plastics’ should

• • • Conform to the IS /ISO 17088 standards
    • Pass biodegradation tests;
    • Pass disintegration tests;
    • Pass eco-toxicity tests

E. That, it could be broadly said that while ‘Biodegradable plastics’ represent the broader class of plastics, capable of degradation through biological process, `Compostable plastics’ degrade under composting conditions; That, as such, it can be concluded that, while all compostable plastics are biodegradable, all biodegradable plastics are not necessarily compostable plastics ; and so compostable plastics may be regarded as a specialised subset of Biodegradable plastics, distinguished only by the environment in which degradation occurs.

F. That, the Central Institute of Petrochemicals Engineering and Technology (CIPET), a recognised testing and certification institution under the CPCB framework, has certified the applicant’s product, viz. `compostable bags and packing materials’, to be in conformity with the IS/ISO 17088 standards, to undergo biological degradation and that it does not leave any toxic or microplastic residue.

G. That, since their product has been tested under IS/ISO 17088 and certified by CIPET, as required by the CPCB, and has achieved 90% bio-degradability, the product qualify as ‘biodegradable bags’ under Chapter 39, and hence eligible to be under S.No.319 of Schedule I of notification — No. 9/2025-CT (R) dated 17.09.2025 attracting rate of 2.5% CGST and SGST, each.

5. The applicant is under the administrative control of State. The concerned authorities of the Centre and State were addressed to report if there are any pending proceedings against the applicant on the issues raised by the applicant in the ARA application and for comments on the issues raised. The jurisdictional Assistant Commissioner, vide letter in Rc.No.145/2026/A2, dated 04.07.2026, has submitted a report on the same and has stated that there are no pending proceedings against the applicant on the issues raised by the applicant in the Advance Ruling application.

6. Personal Hearing

The applicant was given an opportunity to be heard in person on 06.07.2026. Shri CA Anoop Kumar, appeared for the personal hearing as the authorized representative (AR) of M/s. Symphony Polymers (P) Ltd. The AR reiterated the submissions made in their application for advance ruling.

They further brought the attention of the Forum, to a press release (2243871 dated 23.03.2026) titled `GST Rationalisation to Accelerate India’s Green transition’, of the Ministry of Environment, Forest and Climate Change, and stated that the same confirmed the legislative intent behind the rate reduction introduced vide GST 2.0. The AR interpreted that this press release was meant to clarify that, the scope of rate reduction to 5% vide S.No.319 of Notification 9/2025, was specifically intended to apply to compostable carry bags and not merely to bio-degradable bags/paper-based bags. The AR requested that the same may be taken into account while deciding their application for ruling.

The applicant made further submissions dated 13.07.2026 through, wherein they requested that the following points may be added to their record of personal hearing. Accordingly, the relevant portions of the same is extracted below:

i. Product of the Applicant is squarely covered by the Press Release dated 03.2026, which explains the rationale for reduction of GST on biodegradable bags from 18% to 5%, records under the heading “Combating Plastic Pollution”; that the reform “encourages over 200 certified compostable manufacturers to scale up production of starch-based and compostable materials.”

ii. The Applicant is one such certified compostable manufacturer, and that the compostable carry bags manufactured and supplied by the Applicant are starch-based, being manufactured from a blend of Poly Lactic Acid (PLA) and Poly butylene Adipate Terephthalate (PRAT). The Applicant’s product therefore falls precisely within the description used by the Ministry in the Press Release, viz. “starch-based and compostable materials”, and the rate rationalization to 5% under S.No.319 of Notification No. 9/2025 is squarely attracted to the Applicant’s product.

iii. Explanation of PLA and PBAT : Poly lactic Acid (PLA) is a bio-based, compostable polyester derived from the fermentation of plant starches, principally corn starch, sugarcane and similar renewable feedstock. It is the primary starch-derived polymer used as a substitute for conventional petroleum-based plastic.

Polybutylene Adipate Terephthalate (PBAT) is a biodegradable and compostable aliphatic-aromatic copolyester. It is widely blended with Polylactic Acid (PLA), a bio-based biodegradable polymer derived from renewable agricultural feedstocks, to enhance flexibility, toughness, tear resistance, elongation, and heat-sealability. While PLA provides rigidity and strength, PBAT imparts flexibility and ductility, making the blend suitable for compostable films, carry bags, and flexible packaging applications.

A PLA-PBAT blend, compounded with starch, is the standard formulation used in the manufacture of certified compostable carry bags in India. Such carry bags are tested for conformity with IS/ISO 17088:2021 and are certified by the Central Pollution Control Board (CPCB) under the Plastic Waste Management Rules before they can be marketed or sold. The Applicants product is manufactured using this very blend and is accordingly “starch-based” within the meaning of the Press Release.

iv. Physical samples produced before the Authority: Physical samples of the compostable carry bags manufactured by the Applicant were produced and shown to the Hon’ble Authority at the time of the personal hearing on 06.07.2026, for the Authority’s verification of the nature, composition, thickness and labelling/certification markings of the product

7. Discussions and Findings:

7.1 We have carefully examined the submissions made by the applicant in their advance ruling application and the submissions made during the personal hearing. We have also considered the issue involved, the relevant facts and the applicant’s submission / interpretation of law in respect of question on which the advance ruling is sought.

7.2 We find that the query is liable for admission as it gets covered under Section 97(2)(a) and Section 97(2)(b) of CGST/TNGST Act, 2017, under, (a) classification of any goods or services or both; (b) applicability of a notification issued under the provisions of the CGST/TNGST Act, respectively.

7.3 We find that the applicant, M/s Symphony Polymers (P) Ltd., at Plot No. 18, SIDCO Industrial Estate, Manali New Town, Chennai 600103, Tamil Nadu, registered with the GST department with GSTIN 33AAICS0641Q1Z3, is engaged in the business of manufacturing and supply of compostable bags made from polymer blends, and packing materials. The two primary questions that require ruling in the instant application, is that,

(I) Whether the applicant’s compostable bags and packing materials are classifiable under Chapter 39 (if, of plastic/compostable polymer) or Chapter 48 (if of paper) and the appropriate HSN;

(2) Whether supplies of the said compostable bags and packing materials are covered by the entry Paper sacks/Bags and bio-degradable bags’ (Ch 39, 48) in Schedule I of Notification 9/2025-CTR, attracting 5% GST wef 22.09.2025?

We shall now proceed to analyse the facts on hand with the provisions of law and answer each one of the above questions, in that order.

7.4 Question (I) Whether the applicant’s compostable bags and packing materials are classifiable under Chapter 39 (if, of plastic/compostable polymer) or Chapter 48 (if of paper) and the appropriate HSN?

We find that the applicant has submitted a copy of the test report no. 59002 dated 23.10.2019 issued by CIPET: Institute of Plastics Technology, to the applicant, on the sample, viz. Compostable bag, submitted by them for the purpose of testing of material identification and bio degradability. The test report reveals the material identification of the sample product, viz. `Compostable bag’ to be, a blend of Poly Lactic Acid (PLA) and Poly Butylene Adipate Terephthalate (PBAT). Thus the `compostable bag’ in question is made from plastic/polymer materials and not from paper. They are therefore classifiable under Chapter 39, ‘Plastics and articles thereof’, and more specifically, under Chapter heading 3923 2990 – Articles for the conveyance or packing of goods, of other plastics – sacks and bags (including cones)’.

7.5 Question (2) Whether supplies of the said compostable bags and packing materials are covered by the entry Paper sacks/Bags and bio-degradable bags’ (Ch 39, 48) in Schedule I of Notification 9/2025-CTR, attracting 5% GST wef 22.09.2025?

Entry 319 of Schedule I to Notification No.9/2025-Central tax (Rate) dated 17.09.2025, provides a concessional GST rate of 5% for Paper Sacks/Bags and bio-degradable bags’ under Chapter 39 and 48. We find that this concessional rate of 5%, extended to paper sacks/bags falling under Chapter 39/48, is conditional in nature and hence is applicable only if the goods supplied are biodegradable. Therefore, it is imperative to prove that the product supplied is bio-degradable, to avail of this concession.

7.5.1 Bio-degradable’ /’Bio-degradability’, per se is not defined under the GST law. We find that the Central Pollution Control Board (CPCB), a statutory organisation under the Ministry of Environment, Forest and Climate Change. The CPCB, established under the Water (Prevention and Control of Pollution) Act, 1974, and later entrusted with the powers and functions under the Air (Prevention and Control of Pollution) Act, 1981, is responsible for promoting cleanliness of streams and wells, improving air quality, and controlling pollution. It provides technical services to the Ministry of Environment, Forest, and Climate Change and oversees the implementation of Plastic Waste Management Rules. Accordingly, we find it fit to rely upon the Rules, Regulations and definitions made thereunder, to define Bio-degradable’ r Bio-degradability’, in the present context.

A. Clause (ac) of Rule 3 of Plastic Waste Management Rules, 2016, defines Biodegradable plastics as,

“Biodegradable plastics” means plastics, other than compostable plastics, which undergoes degradation by biological processes under ambient environment (terrestrial or in water) conditions, without leaving any micro plastics, or visible, or distinguishable or toxic residue, which. has adverse environment impacts, adhering to laid down standards of Bureau of Indian Standards and certified by the Central Pollution Control Board,”

B. Rule 4(h) (Conditions) of the Plastic Waste Management Rules, 2016, stipulates that the manufacturers or sellers of biodegradable plastics carry bags or commodities or both have to obtain certificate from the Central. Pollution Control Board before marketing or selling biodegradable plastics carry bags or commodities or both.

C. Rule 10 of the Plastic Waste Management (Second Amendment) Rules, 2022, prescribes the protocols for biodegradable plastic materials, extracted hereunder:-

“10. Protocols for compostable and biodegradable plastic materials.-

(1) Determination of the degree of degradability and degree of disintegration of plastic material shall be as per the protocols of the Indian Standards listed in Schedule I

(2) The compostable plastic materials shall conform to the IS / ISO 17088:2021, as amended from time to time.

(3) The biodegradable plastics shall conform to the standard notified by the Bureau of Indian Standards and certified by the Central Pollution Control Board.

(4) Until a standard referred to in sub-rule (3) is notified by the Bureau of Indian Standards, biodegradable plastics shall conform to tentative Indian Standard IS 17899 T:2022 as notified by the Bureau of Indian Standards.

(5) As a transitory measure, provisional certificate for biodegradable plastics, shall be issued by the Central Pollution Control Board, in cases, where an interim test report is submitted, for an ongoing test, which covers the first component of the IS 17899 T:2022 relating to biodegradability given at Si. No. (i) or Sl. No. (ii) of Table 1 or Sl. No. (i) of Table 2 of the IS 17899 T:2022: Provided that the provisional certi_ficate shall be valid till 30th June 2023 with the condition that production or import of biodegradable plastics shall cease after the 31st day of March, 2023.

(6) The interim test report shall be obtained from the Central Institute of Petrochemical Engineering and Technology or a laboratory recognised under the Laboratory Recognition Scheme, 2020, of the Bureau of Indian Standards or laboratories accredited for this purpose by the National Accreditation Board for Testing and Calibration Laboratories, and they shall certify the bio-degradation of plastic is in line with IS 17899 T:2022.”

7.5.2 It can be seen from the above legal provisions, that ‘Biodegradable plastics’ have to confoiin to tentative Indian Standard IS:17899 T:2022, as notified by the Bureau of Indian Standards. (relevant portion extracted below)

IS 17899 T: Assessment of Biodegradability of Plastics in Varied Conditions (Tentative Indian Standard).

1 Scope:

1.1 This provisional standard specifies the procedures and assessment of biodegradability of plastics under varied conditions. This provisional standard addresses the following aspects:

a) Biodegradation

b) Negative effects of resulting biomass on terrestrial plant growth/organism.

c) Negative effects of the quality of the resulting biomass including the presence of high levels of regulated heavy metals.

1.2 The provisional standard is applicable for assessing the biodegradability of plastics under aerobic, anaerobic conditions.

1.3 The provisional standard is not applicable for assessing the biodegradability of plastics under marine environment.

1.4 The assessment of biodegradability of plastic, if done through composting conditions only, vide IS/ISO 14855-1 and IS/ISO 14855-2, the plastic shall be certified as compostable plastic, and not as biodegradable plastic as defined under PWM Rules 2016, as amended.

1.5 This provisional standard excludes compostable plastics as per IS/ISO 17088, as per PWM Rules 2016, as amended.

7.5.3 Further we find that the CPCB, has prescribed a Standard Operating Procedure (SOP) for issuing Certificate of Manufacturers/Sellers of Biodegradable Plastic Carry bags and Commodities, under Rule 4(h) of Plastic Waste Management (PWM) Rules, 2016.

• • • As per this SOP, the manufacturer/seller of biodegradable plastic carry bags and commodities can apply to the CPCB for registration in Form A(Manufacturer)/Form B (Seller) along with the prescribed documents, which include,

i. PAN 8s GST of the Company

ii. Aadhar of Authorized person

iii. Process flow diagram

iv. Consents under Air / Water Act issued by SPCB/ PCC

v. Registration Certificate for production of Biodegradable carry bags or commodities or both issued by concerned SPCB/PCC under Rule 13(i) of Plastic Waste Management Rules, 2018

vi. Geo-tagged pictures of raw material storage area, production area and product dispatch area

vii. Geo-tagged pictures of plant machinery

viii. Copy of Electricity Bill

ix. Copy of document giving details of pollution control measures

x. Documents supporting procurement of raw material ( Tax invoice etc).

• • • Id. Test reports as per Indian Standards IS/ISO 17899: 2022. -Testing has
      to be done at CIPET or a laboratory recognised under the Laboratory Recognition Scheme, 2020, of the Bureau of Indian Standards or laboratories accredited for this purpose by the National Accreditation Board for Testing and Calibration Laboratories.
    • The SOP also details the steps for processing of applications by CPCB, for issue of certificate or reject the application in cases where information/ document submitted is found to be false/irrelevant.
    • The validity of the certificate issued by CPCB, to manufacture/sell biodegradable commodities, is also subject to compliance of the conditions stipulated.
    • A monitoring mechanism has also been prescribed in the SOP, to ensure compliance of all the stipulated conditions.
    • Finally, the CPCB is also empowered to cancel / suspend the certificate of the manufacturer/seller, if they fail to comply with any of the stipulated conditions, after due process of law.

7.5.4 In the backdrop of the above requisite legal stipulations issued for the manufacture of bio-degradable commodities, we now proceed to examine if the compostable bags and packing materials of the applicant, comply to such stipulations and if they are covered by entry 319 – Paper sacks/Bags and bio-degradable bags’ (CH 39,48) in Schedule I of Notification 9/2025-CTR, attracting 5% GST wef 22.09.2025.

> We find that the applicant has submitted a test report No.59002 dated 23.10.2019 issued by CIPET, Institute of Plastics Technology, on their sample, viz. Compostable bag, submitted for the purpose of material identification and bio degradability. The test report reveals the material identification in the sample product, viz. ‘Compostable bag’, to be a blend of Poly Lactic Acid (PLA) and Poly Butylene Adipate Terephthalate (PBAT). The test report further reveals the heavy metal concentration in the sample after `ultimate aerobic biodegradation’ and the same are reported to be in conformity with IS/ISO-17088, which is the standard prescribed for `compostable plastics’ (Rule 10(2) of PWM Rules, 2016, as amended. (extracted under Para 7.5.1(C) above).

> We further find that the applicant has also submitted a certificate in. No.B-17011/7/PWM(COMP)/2021(SPPL) dated 02.03.2021, issued to them by Central Pollution Control Board (CPCB), certifying that they have fulfilled the criteria as per the revised SOP, to manufacture compostable carry bags.

Thus, it is unambiguously clear that the applicant holds certification issued by the competent authority to manufacture ‘Compostable carry bags’, that conform to IS/ISO-17088.

However, as seen from the foregoing discussions, in order to avail the exemption under S.No.319 of Schedule I of the Notification 9/2025-CT(R) dated 17.09.2025, it is imperative that the goods are ‘biodegradable’, and conform to IS/ISO-17899: 2022.

We find that the applicant has not come forth with any documentary evidence/ valid certification issued by CPCB to manufacture ‘Biodegradable carry bags/ commodities’ with the IS/ISO-17899 T:2022 certification from the Bureau of Indian Standards in respect of the products that they manufacture, to prove that they are biodegradable products.

Further, sub-clause 1.5 (Scope) of “IS/ISO-17899 T : Assessment of Biodegradability of Plastics in Varied Conditions (Tentative Indian Standard)”, issued by the Bureau of Indian Standards, specifically excludes compostable plastics as per IS/ISO 17088, as per PWM Rules 2016, (as aniended),from its scope. Thus it is clear that the compostable bags supplied by the applicant do not fall under the category of ‘Biodegradable bags’ mentioned in entry 319 of Schedule I to Notification 9/2025-CT (R) dated 17.09.2025.

Therefore, we conclude that the supplies of the compostable bags and packing materials are not covered by the entry 319-Paper sacks/Bags and bio-degradable bags’ (Ch 39, 48) in Schedule I of Notification 9/2025-CTR dated 17.09.2025.

Further, in as much as the fundamental element of compliance viz. the product to be biodegradable, as per statutory norms explained above, is not fulfilled, we find that the additional submissions made by the applicant vide letter dated 13.07.2026, with regard to the press release, PLA/PBAT etc. is inconsequential.

8. In view of the above, we rule as under:

RULING

(1) Whether the applicant’s compostable bags and packing materials are classifiable under Chapter 39 (if, of plastic/ compostable polymer) or Chapter 48 (if of paper) and the appropriate ISSN?

Ans. As detailed under para 7.4, the `compostable bag’ is made from polymer materials, including PLA and PBAT, and hence are classifiable under Chapter 39, ‘Plastics and articles thereof, and more specifically, under Chapter heading 3923 2990 — Articles for the conveyance or packing of goods, of other plastics – sacks and bags (including cones)’.

(2) Whether supplies of the said compostable bags and packing materials are covered by the entry ‘Paper sacks/Bags and bio-degradable bags’ (Ch 39, 48) in Schedule I of Notification 9/2025-CTR, attracting 5% GST wef 22.09.2025?

Ans. No, As detailed under para 7.5.4, the supplies of the compostable bags and packing materials are not covered by the entry 319 – ‘Paper sacks/Bags and bio-degradable bags’ (Ch 39, 48) in Schedule I of Notification 9/2025-CTR dated 17.09.2025.