In re OPPO Mobiles India Private Limited (CAAR Delhi)
Summary: The Customs Authority for Advance Rulings, Delhi considered M/s OPPO Mobiles India Private Limited’s application seeking an Advance Ruling on the classification of a proposed import described as a “back cover assembly with battery” for tablet PCs. The application was received on 07.04.2026 under Section 28-H of the Customs Act, 1962. The applicant proposed classification under CTH 8473 30 99, treating the assembly as a composite part of an automatic data processing machine. The jurisdictional Commissionerate contended that the assembly was classifiable under CTH 8507.
The proposed assembly comprises eleven components: middle frame, camera lenses, flash lens, conductive cloth, thermal conductive pads, plastic bracket, waterproof label, plastic sleeve for the power key, self-adhesive foam sheets, a lithium-ion battery and back cover. The applicant stated that the assembly provides structural accommodation and fixation, protection from impact and dust, power supply and heat dissipation, and is intended for use with tablet PCs. The applicant relied on the Customs Tariff Act, 1975, the General Rules for Interpretation and Section XVI Note 2(b), contending that the integrated battery was only one component of a composite article whose essential character was structural.
The jurisdictional Commissionerate disagreed. It relied on Section XVI Note 2(a), the exclusion of “covers, carrying cases and the like” from heading 8473, the General Explanatory Note to Section XVI concerning electric accumulators assembled into battery packs, and the Explanatory Note to heading 85.07. It submitted that the lithium-ion battery was specifically covered by heading 8507 and that Note 2(a) had to be applied before any essential-character exercise under GRI 3(b). It also noted that no component-wise value or weight break-up had been furnished to support the applicant’s essential-character claim.
The Authority considered the application, the Commissionerate’s comments, the applicant’s rebuttal dated 17.08.2026 and the record of the virtual personal hearing held on 15.07.2026. It found the application maintainable. For the classification question, the Authority first recognised that tablet computers are classifiable under heading 8471, consistently with Circular No. 20/2013-Customs dated 14.05.2013.
The Authority then distinguished heading 8473 from the goods as presented. Heading 8473 expressly excludes “covers, carrying cases and the like”. The Authority held that the back cover and middle frame, viewed with the incorporated battery and associated components, could not be brought within heading 8473 merely because they were designed for use with a tablet PC. It also applied Section XVI Note 2(a), observing that goods which are themselves covered by a specific heading of Chapter 84 or 85 must be classified in that specific heading before resort to Note 2(b). The Authority relied on Collector of Central Excise v. Delton Cables Ltd., 2005 (181) E.L.T. 373 (S.C.), for the sequential application of the Section Note.
The decisive reasoning concerned Chapter 85 Note 3. The Authority found that the lithium-ion battery constituted the electric accumulator and that the thermal pads, conductive cloth, foam sheets, plastic bracket and waterproofing components had a direct functional nexus with its securing, insulation, thermal management and protection. The middle frame and back cover were also treated as portions of the protective housing of the tablet in which the accumulator was to be used. On that basis, the assembly as presented fell within the extended meaning of “electric accumulators” under heading 8507. The Authority therefore applied Note 2(a) to Section XVI and rejected the applicant’s proposed heading 8473 30 99.
At the sub-heading level, the Authority held that lithium-ion accumulators fall under sub-heading 8507 60 and that the corresponding eight-digit tariff item is 8507 60 00. Accordingly, the final ruling classified the “Back Cover Assembly with Battery/Battery Integrated Rear Cover” in its entirety under CTH 8507, specifically tariff item 8507 60 00, and not under CTH 8473 30 99.
Cases Discussed
- Collector of Central Excise v. Delton Cables Ltd. & Anr., (2005) 12 SCC 284; 2005 (181) E.L.T. 373 (S.C.) — cited for the sequential application of Section XVI Note 2(a) before Note 2(b).
FULL TEXT OF THE ORDER OF CUSTOMS AUTHORITY FOR ADVANCE RULINGS, DELHI
M/s OPPO Mobiles India Private Limited, 05th Floor, Tower-B, Building No. 08, DLF Cyber City, Gurugram, Haryana-122002 having IEC No. 0513070605 and PAN-AABCO9247K (the applicant, in short) filed the instant application in Form CAAR-I before the Customs Authority for Advance Rulings, New Delhi (CAAR, in short) for seeking advance ruling. The complete application was received in the Secretariat of the CAAR, New Delhi on 07.04.2026 along with enclosures in terms of Section 28-H(1) of the Customs Act, 1962 (hereinafter referred to as the ‘Act’)
1.1. The applicant’s submissions are as given below:-
1.2. M/s OPPO MOBILES INDIA PRIVATE LIMITED having office at STH FLOOR, TOWER- B, BUILDING NO-8, DLF CYBER CITY, GURGAON, Gurugram, Haryana, 122002 and factory located at Plot no, 01 Kasna Ecotech-VIl, Greater Noida Industrial Development, Gautam Budha ‘Nagar 201310 (hereinafter referred as ‘the applicant’) is willing to import back cover assembly with battery of tablet PCs.
1.3. It is submitted that the question arises due to doubt in the correct tariff classification of the product based on its nature and end use, and the applicant seeks clarity under the classification under the custom tariff Act 1975.Since the correct classification of the subject goods is in question, the same is required to be determined by applying the General Rules for Interpretation of the Import Tariff, read with the Customs Tariff Act, 1975,
1.4. It is respectfully submitted at the outset that the classification of the subject goods under India’s Customs Tariff should be determined in accordance with the General Rules for the Interpretation of the Import Tariff, along with the relevant Section Notes, Chapter Notes, and Explanatory Notes of the Customs Tariff Act, 1975, which are reproduced below:
For this purpose, the Rules of Interpretation have been provided of which Rule | reads as follows
“1, The titles of Sections, Chapters and sub-chapters are provided for ease of reference only; ‘for legal purposes, classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes and, provided such headings or Notes do not otherwise require, according to the following provisions:
2. (a) Any reference in a heading to an article shall be taken to include a reference to that ‘article incomplete or unfinished, provided that, as presented, the incomplete or unfinished articles has the essential character of the complete or finished article. It shall also be taken to include a reference to that article complete or finished (or falling to be classified as complete ‘finished by virtue of this rule), presented unassembled or disassembled.
(b) Any reference in a heading to a material or substance shall be taken to include a reference to mixture or combinations of that material or substance with other materials or substances. Any reference to goods of a given material or substance shall be taken to include a reference {0 goods consisting wholly or partly of such material or substance. The classification of goods consisting of more than one material or substance shall be according to the principles of rule 3. 3. When by application of rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be affected as follows.
3. (a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods or to part only of the items in a set put up for retail sale, those headings are to be regarded.as equity specific in relation to those goods, even if one of them gives a more complete oy precise de goods.
(b) Mixtures, composite goods consisting of different materials or made up of different ‘components, and goods put up in sets for retail sale, which cannot be classified by reference to (a), shall be classified as if they consisted of the material or component which gives them their essential character, in so far as this criterion is applicable.
(c) When goods cannot be classified by reference to (a) or (b), they shall be classified under the heading which occurs last in numerical order among those which equally merit consideration.
4. Goods which cannot be classified in accordance with the above rules shall be classified under the heading appropriate to the goods to which they are most akin
5. In addition to the foregoing provisions, the following rules shall apply in respect of the goods referred to therein: (a) Camera cases, musical instrument cases, gun cases, drawing instrument cases, necklace cases and similar containers, specially shaped or fitted to contain a specific article or set of articles, suitable for long-term use and presented with the articles for which they are intended, shall be classified with such articles when of a kind normally sold therewith. This rule does not, however, apply to containers which give the whole its essential character; (b) Subject to the provisions of (a) above, packing materials and packing containers presented with the goods therein shall be classified with the goods ifthey are of a kind normally used for packing such goods. However, this provision does not apply when such packing materials or packing containers are clearly suitable for repetitive use.
6. For legal purposes, the classification of goods in the sub-headings of a heading shall be determined according to the terms of those subheadings and any related subheadings Notes and, mutatis mutandis, to the above rules, on the understanding that only sub headings at the same level are comparable. For the purposes ofthis rule the relative Section and Chapter Notes also apply, unless the context otherwise requires.”
1.5. In the present case, the subject goods under consideration are a back cover assembly with battery, specifically designed for use in tablet PCs. The tablet PC components are as follows:
| S.No. | Description | Unit | Quantity |
|---|---|---|---|
| 1 | Middle Frame | PCS | 1 |
| 2 | Camera Lens | PCS | 2 |
| 3 | Flash Lens | PCS | 1 |
| 4 | Conductive Cloth | PCS | 3 |
| 5 | Thermal Conductive Pad | PCS | 3 |
| 6 | Plastic Bracket | PCS | 1 |
| 7 | Water-Proof Label | PCS | 1 |
| 8 | Plastic Sleeve For Power Key | PCS | 1 |
| 9 | Self-Adhesive Foam Sheet | PCS | 4 |
| 10 | Lithium-Ion Battery | PCS | 1 |
| 11 | Back Cover | PCS | 1 |
Functions:
A. Provide functions of structural accommodation and fixation for components such as PCBs, speakers, display screen, battery, and cameras, etc. of the tablet PCs;
B. Protect components from external impacts and dust contamination,
C. Power supply function,
D. Heat dissipation function.
1.6. It is Submitted that These functions are all indispensable for the tablet PCs. Therefore, this back cover assembly with battery is a component specifically designed for the tablet PCs and has comprehensive functions.
1.7. Moreover, when this back cover assembly with battery combined with other components such as PCBs, speakers, display screen, battery, and cameras, etc, it becomes a complete tablet PCs capable of automatically processing data,
1.8. Additionally, the product will be imported and used to replace the damaged tablet PCs of ‘consumers at the after-sales service store.
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1.9. Additionally, the back cover assembly is not capable of independent use. Accordingly, its classification is examined below in terms of the applicable General Rules for Interpretation.
1.10. Furthermore, the view is that the back cover assembly with battery should be classified considering its essential character, its exclusive use as a part of tablet PCs, and the relevant provisions of the Customs Tariff Act, Section Notes, Chapter Notes, and General Rules for Interpretation (GRI).
1.11. Since the correct classification of the subject goods is in question, the same is required to be determined by applying the General Rules for Interpretation of the Import Tariff, read with the Customs Tariff Act, 1975,
1. The titles of Sections, Chapters and sub-chapters are provided for ease of reference only; for legal purposes, classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes and, provided such headings or Notes do not otherwise require, according to the following provisions:
2a)Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as presented, the incomplete or unfinished articles has the essential character of the complete or finished article. It shall also be taken to include a reference to that article complete or finished (or falling to be classified as complete or finished by virtue of this rule), presented unassembled or disassembled.
1.12, Moreover, as provided by the customs tariff of India, Section XVI Notes which are reproduced below :~
2.- Subject to Note 1 to this Section, Note 1 to Chapter 84 and Note 1 to Chapter 85, parts of ‘machines (not being parts of the articles of heading 84.84, 85.44, 85.45, 85.46 or 85.47) are t0 be classified according to the following rules :
(a) Parts which are goods included in any of the headings of Chapter 84 or 85 (other than headings 84.09, 84.31, 84.48, 84.66, 84.73, 84.87, 85.03, 85.22, 85.29, 85.38 and 85.48) are in all cases to be classified in their respective headings.
(b) Other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading (including a machine of heading 84.79 or 85.43) are 10 be classified with the machines of that kind or in heading 84.09, 84.31, 84.48, 84.66, 84.73, 85.03, 85.22, 85.29 or 85.38 as appropriate. However, parts which are equally suitable for use principally with the goods of headings 85.17 and 85.25 to 85.28 are to be classified in heading 85.17, and parts which are suitable for use solely or principally with the goods of heading 85.24 are to be classified in heading 85.29.
(c) All other parts are to be classified in heading 84.09, 84.31, 84.48, 84.66, 84.73, 85.03, 85.22, 85.29 or 85.38 as appropriate or, failing that, in heading 84.87 or 85.48.
1.13. Furthermore, in this context, Section XVI of the Indian Customs Tariff, read in conjunction with Chapter 84 (Nuclear Reactors, Boilers, Machinery, and Mechanical Appliances), as well as the relevant chapter notes reproduced below.
Note:- (6.4) For the purposes of heading 8471, the expression “automatic data processing ‘machine” means machine capable of
I. storing the processing programme or programmes and at least the data immediately necessary for the execution of the programme.
II. being freely programmed in accordance with the requirements of the user;
III. performing arithmetical computations specified by the user; and
IV. executing, without human intervention, a processing programme which requires them t0 ‘modify their execution, by logical decision during the processing run,
(B) Automatic data processing machines may be in the form of systems consisting of a variable number of separate units
(C) Subject to paragraphs (D) and (E), a unit is to be regarded as being part of an ‘automatic data processing system if it meets all of the following conditions:
I. it is of a kind solely or principally used in an automatic data processing system.
II. it is connectable to the central processing unit either directly or through one or more other units; and
III. it can accept or deliver data in a form (codes or signals) which can be used by the system.
Separately presented units of an automatic data processing machine are to be classified in heading 8471. However, keyboards, X-Y co-ordinate input devices and disk storage ants which satisfy the conditions of (i) and (it) above, are in all cases to be classified as units of heading 8471.
(D) Heading 8471 does not cover the following when presented separately, even if they ‘meet all of the conditions set forth in paragraph (C):
I. printers, copying machines, facsimile machines, whether or not combined;
II. apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network);
III. loudspeakers and microphones.
IV. television cameras, digital cameras and video camera recorders.
V. ‘monitors and projectors, not incorporating television reception apparatus
(E) Machines incorporating or working in conjunction with an automatic data processing ‘machine and performing a specific function other than data processing are to be classified in the headings appropriate to their respective functions or, failing that, in residual headings
1.14. Additionally, itis proposed that the headings and subheadings delineated in the Indian Customs Tariff, as detailed in the following table, be subjected to thorough analysis.
| HS Code | Description | Duty |
|---|---|---|
| 8471 30 | Portable automatic data processing machines, weighing not more than 10 kg, consisting of at least a central processing unit, a keyboard and a display | |
| 8471 30 10 | Personal computer | Free |
| 8471 30 90 | Other | Free |
| 8471 41 | Other automatic data processing machines comprising in the same housing at least a central processing unit and an input and output unit, whether or not combined | |
| 8471 41 10 | Micro computer | Free |
| 8471 41 20 | Large or main frame computer | Free |
| 8471 41 90 | Other | Free |
| 8471 49 00 | Presented in the form of systems | Free |
| 8471 50 00 | Processing units other than those of sub-headings 8471 41 or 8471 49, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units | Free |
| 8471 30 | Portable automatic data processing machines, weighing not more than 10 kg, consisting of at least a central processing unit, a keyboard and a display | |
| 8471 30 10 | Personal computer | Free |
| 8471 30 90 | Other | Free |
| 8471 41 | Other automatic data processing machines comprising in the same housing at least a central processing unit and an input and output unit, whether or not combined | |
| 8471 41 10 | Micro computer | Free |
| 8471 41 20 | Large or main frame computer | Free |
| 8471 41 90 | Other | Free |
| 8471 49 00 | Presented in the form of systems | Free |
| 8471 50 00 | Processing units other than those of sub-headings 8471 41 or 8471 49, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units | Free |
1.15, Importantly this back cover assembly with battery contains multiple key components (¢.g., back cover, middle frame, battery) constituting a substantial part of the tablet PC (The tablet PC is classified under 84713010-Personal computer). This back cover assembly with battery possesses the essential character of a tablet PC part (providing structural support, protection, heat dissipation, power supply, etc.), aligning with the scope of heading 8473.
| HS Code | Description | Duty |
|---|---|---|
| 8473 10 00 | Omitted – Parts and accessories of the machines of heading 8470 | |
| 8473 21 00 | Of the electronic calculating machines of sub-heading 8470 10, 8470 21 or 8471 29 | Free |
| 8473 29 00 | Other | Free |
| 8473 30 10 | Microprocessors | Free |
| 8473 30 20 | Motherboards | Free |
| 8473 30 30 | Other mounted printed circuit boards | Free |
| 8473 30 40 | Head stack | Free |
| 8473 30 91 | Network access controllers | Free |
| 8473 30 92 | Graphic and intelligence based script technology (GIST) cards for multilingual computers | Free |
| 8473 30 99 | Other | Free |
| 8473 40 10 | Parts of duplicating, hectograph or stencil machines | 13% |
| 8473 40 90 | Other | 15% |
| 8473 50 00 | Parts and accessories equally suitable for use with | Free |
1.16. Nevertheless, since lithium-ion batteries are classified under 8507, it is advisable to consult the Explanatory Notes for the relevant chapter: “Electrical machinery and equipment and parts thereof; sound recorders and reproducers, television image and sound recorders and reproducers, and parts and accessories of such articles.”
3. For the purposes of heading 8507, the expression “electric accumulators” includes those presented with ancillary components which contribute to the accumulator’s function of storing and supplying energy or protect it from damage, such as electrical connectors, temperature control devices (for example, thermistors) and circuit protection devices. They may also include a portion of the protective housing of the goods in which they are to be used.
1.17. It is further submitted that application of WCO GRI Rule | leads to the classification of this back cover assembly with battery as a tablet PC part under heading 8473.
1.18. The lithium-ion battery alone falls under 8507 but, as an integrated part of the assembly serving the tablet PC’s overall function and not being the dominant characteristic, classification under 8507 is incorrect. While components like the lithium-ion battery could be classified separately (e.2., under 8507), within this composite assembly, they serve the overall function of the tablet PC part According to Rule 2(b) and Rule 3(b), the assembly should not be disassembled for classification and belongs under 8473.
1.19. Itis also submitted that, in the applicant’s view, the subject back cover assembly with battery of tablet PC is classifiable under Chapter 84. Therefore, to clarify the matter and to avoid any future litigation, the applicant sought this ruling.
1.20. Accordingly, the applicant seeks an Advance Ruling to confirm the correct classification and legal position, so as to ensure uniformity, certainty, and compliance in customs assessment.
1.21. Nature of Activity (Proposed/present) on which the advance ruling is sought Question on which advance ruling is sought
1.21.1. The matter involves determining the correct import classification for back cover assemblies with batteries used in tablet PCs. Because there is uncertainty about which tariff category applies given the product’s features and purpose, the applicant is requesting clarification under Customs law.
2. Comments of the Port Commissionerate:
2.1. As per the provision of CAAR Regulation, 2021, the complete application of the applicant was provided to the concerned Custom Port, and requested to furnish the requisite comments in the instant matter. The port authority vide letter dated furnished its comments, as follows:-
2.2. Preliminary Observations Upon Perusal Of The Application:
2.2.1. The point-wise preliminary observations on maintainability, on the pattern of Section 28-1(1) of the Customs Act, 1962 read with Regulation 8(7) of the Customs Authority for Advance Rulings Regulations, 2021, are set out below.
(i) Eligibility of the applicant, in terms of Section 28-E(c) of the Customs Act, 1962: Yes. M/s OPPO Mobiles India Private Limited is a valid applicant within the meaning of Section 28-E(c) of the Customs Act, 1962, holding IEC No. 0513070605.
(ii) Applicability of proviso to Section 28-1(2) of the Customs Act, 1962: As per records available with this Commissionerate, no question identical to the one raised in the present application is pending in the Applicant’s case before any officer of Customs, the Appellate Tribunal or any Court, and the declarations to this effect at Points 11 and 12 of Form CAAR-1 are in order.
(iii) Nature of activity — ongoing/proposed: As per Point 6/7 of Form CAAR-1, the Applicant has correctly declared that the activity is presently proposed and not yet undertaken, the goods described being intended for future import for use as a component—i manufacture/assembly/after-sales service of tablet PCs. No infirmity is noticed on this declaration.
(iv) Comments on the merits of the question raised, along with all materials in support thereof: The question raised — classification of goods under the Customs Tariff Act, 1975 ~ is squarely a question covered under Section 28-H(2)a) of the Customs Act, 1962. Detailed ‘comments on merits, along with the materials in support thereof, are set out in Parts I to V below.
The application is accordingly maintainable.
2.2.2 Without prejudice to the above, on merits of the classification question raised, the comments of this Commissionerate are set out below.
2.3. PART I: FACTUAL BACKGROUND AND NATURE OF GOODS
2.3.1. M/s OPPO Mobiles India Private Limited (‘the Applicant’) proposes to import a “back cover assembly with battery” for use as a component in the manufacture/assembly/sale/after-sales service of tablet PCs marketed under the ‘realme” brand. The product, per the technical data sheet and Bill of Materials enclosed with the application, comprises eleven (11) distinct components, namely: (i) middle frame; (ii) camera lens ~ 2 pes; (ii) flash lens; (iv) conductive cloth — 3 pes; (v) thermal conductive pad ~ 3 pes; (vi) plastic bracket; (vii) water-proof label; (viii) plastic sleeve for power key; (ix) self-adhesive foam sheet ~ 4 pcs;(x) lithium-ion battery – 1 pc; and (xi) back cover- 1 pc.
Exhibit 1: Photograph of the back cover assembly with battery, as annexed by the Applicant to its ‘Statement of Facts (Form CAAR- I, Annexure). The lithium-ion cell (‘SUPERVOOC’ branded) is seen occupying the substantial majority of the internal surface area of the assembly.
| No. | Description | Unit | Quantity |
|---|---|---|---|
| 1 | Middle Frame | PCS | 1 |
| 2 | Camera Lens | PCS | 2 |
| 3 | Flash Lens | PCS | 1 |
| 4 | Conductive Cloth | PCS | 3 |
| 5 | Thermal Conductive Pad | PCS | 3 |
| 6 | Plastic Bracket | PCS | 1 |
| 7 | Water-Proof Label | PCS | 1 |
| 8 | Plastic Sleeve For Power Key | PCS | 1 |
| 9 | Self-Adhesive Form Sheet | PCS | 4 |
| 10 | Lithium-Ion Battery | PCS | 1 |
| 11 | Back Cover | PCS | 1 |
Functions:
A. Provide functions of structural accommodation and fixation for components such as PCBs, speakers, display screen, battery, and cameras, etc. of the tablet PCs;
B. Protect components from external impacts and dust contamination.
C. Power supply function.
D. Heat dissipation function.
Exhibit 1: Photograph of the back cover assembly with battery, as annexed by the Applicant to its Statement of Facts (Form CAAR-1, Annexure). The lithium-ion cell (“SUPERVOOC” branded) is seen occupying the substantial majority of the internal surface area of the assembly.
2.3.2. The Applicant states the assembly performs four functions: (A) structural accommodation and fixation for the PCB, speaker, display screen, battery and camera of the tablet; (B) protection of internal components from impact and dust; (C) power supply; and (D) heat dissipation. The Applicant further submits that the assembly is not capable of independent use, and that the parent tablet PC is classifiable under CTH 8471 30 10 (Personal computer).
2.3.3. The Applicant has sought a ruling under Section 28H(2)(a) that the assembly, as a composite article, be classified under CTH 8473 (parts and accessories of automatic data processing machines), by application of GRI 1, GRI 2(b)/3(b), and Note 2(b) to Section XVI ~ treating the lithium-ion battery as merely one constituent of a composite good whose essential character is that of a structural tablet-PC part, notwithstanding that a lithium-ion battery, presented separately, would fall under CTH 8507.
2.4. PART I: COMMENTS ON QUESTIONS OF LAW ~ APPLICABLE LEGAL FRAMEWORK
2.4.1. Section 12 of the Customs Act, 1962 read with Section 2 of the Customs Tariff Act, 1975 CTA’) provides for levy of duty at the rates specified in the First Schedule to the CTA, organised on the Harmonized System of Nomenclature. Classification is governed by the General Rules for Interpretation (‘GRI’), applied sequentially, GRI | being foundational: classification is determined “according to the terms of the headings and any relative Section or Chapter Notes,” and only where the headings/Notes do not resolve the matter do GRI 2 to 5 come into play. GRI 6 governs sub-heading classification, mutatis mutandis, to the same principles.
2.4.2, Section XVI of the CTA (Chapters 84 and 85) is the relevant Section. The following provisions ‘are material:
(a) Text of Heading 8473: “Parts and accessories (other than covers, carrying cases and the like ) suitable for use solely or principally with machines of headings 8469 to 8472.” The exclusion of “covers, carrying cases and the like” is part of the statutory heading text itself and is therefore a GRI-I-level bar, before any GRI 2/3 essential-character analysis.
(b) Note 2(a) to Section XVI: “Parts which are goods included in any of the headings of Chapter 84 or 85 (other than headings 84.09, 84.31, 84.48, 84.66, 84.73, 84.87, 85.03, 85.22, 85.29, 85.38 or 85.48) are in all cases to be classified in their respective headings.” Heading 8473 is itself among the headings excluded from this list ~ confirming that 8473 is a residual parts heading which is reached only where Note 2(a) does not independently place the article in a specific heading of Chapter 84/85. Heading 8507 (electric accumulators, including lithium-ion) is not among the excluded headings, and a lithium-ion battery is a specifically named good of that heading.
(c) Note 2(b) to Section XVI: applies only “where Note 2(a) does not apply”- i.e sequentially, as a fallback.
(d) Note 3 to Section XVI: composite machines/multi-function machines are classified as if consisting only of the component, or as being the machine, performing the principal function.
(e) Chapter 84 Note 6(A): defines “automatic data processing machine” for heading 8471 purposes.
(A) For the purposes of heading 8471, the expression “automatic data processing ‘machine” means machine capable of
(i) storing the processing programme or programmes and at least the data immediately necessary for the execution of the programme;
(ii) being freely programmed in accordance with the requirements of the user;
(iii) performing arithmetical computations specified by the user;
(iv) executing, without human intervention, a processing programme which requires them to modify their execution, by logical decision during the processing run.
(B) Automatic data processing machines may be in the form of systems consisting of a variable number of separate units.
(C) Subject to paragraphs (D) and (E), a unit is to be regarded as being part of an automatic data processing system if it meets all of the following conditions
(i) it is of a kind solely or principally used in an automatic data processing system;
(ii) it is connectable to the central processing unit either directly or through one or more other units; and
(iii) it is able to accept or deliver data in a form (codes or signals) which can be used by the system. Separately presented units of an automatic data processing ‘machine are to be classified in heading 8471. However, keyboards, X-Y co-ordinate input devices and disk storage units which satisfy the conditions of (i) and (iii) above, are in all cases to be classified as units of heading 847 1.
(D) Heading 8471 does not cover the following when presented separately, even if they ‘meet all of the conditions set forth in paragraph (C):
(i) printers, copying machines, facsimile machines, whether or not combined:
(ii) apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network);
(iii) loudspeakers and microphones.
(iv) television cameras, digital cameras and video camera recorders.
(v) ‘monitors and projectors, not incorporating television reception apparatus
(E) Machines incorporating or working in conjunction with an automatic data processing ‘machine and performing a specific function other than data processing are to be classified in the headings appropriate to their respective functions or, failing that, in residual headings
(f) General Explanatory Note to Section XVI, Part (ID — “Parts” [commentary on Section Note 2], HSN Explanatory Notes, 2022 (7th) Edition, Vol. 4 (as paginated in the departmental copy, at the General Notes to Section XVI immediately preceding Chapter 84): after stating that parts which “in themselves constitute an article covered by a heading of this Section (other than headings 84.87 and 85.48)… are in all cases classified in their own appropriate heading even if specially designed to work as part of a specific machine,” the Note gives an enumerated list of examples. Item (10) on that list reads:
“(10) Electric accumulators assembled into battery packs (heading 85.07).”
(g) Explanatory Note to heading 84.73: in addition to the exclusion in the heading text itself, the Explanatory Note states in terms:
“the heading excludes covers, carrying cases and felt pads; these are classified in their appropriate headings.”
(h) Explanatory Note to heading 85.07: the Note states:
“Accumulators containing one or more cells and the circuitry to interconnect the cells amongst themselves, often referred to as ‘battery packs’, are covered by this heading, whether or not they include any ancillary components which contribute to the accumulator’s function of storing and supplying energy, or protect it from damage, such as electrical connectors, temperature control devices (e.g., thermistors), circuit protection devices, and protective housings. They are classified in this heading even if they are designed for use with a specific device.”
The same Note further records, under ‘Parts,’ that the heading “also covers parts of accumulators, e.g., containers and covers.”
2.4.3. CBIC Circular No. 20/2013-Cus. dated 14.05.2013 has settled, by application of Section XVI Note 3 and Chapter 84 Note 6(A), that “tablet computers” are classifiable under heading 8471, sub- heading 8471 30, even where the device incorporates incidental cellular/voice-calling functionality, since the ADP function remains the principal function and voice-calling is only a supplementary function riding on the tablet’s operating system. This Commissionerate has no observation adverse to the Applicant on this limited point (see Part IV, Issue 2 below).
2.5. PART II]: COMMENTS ON THE CLASSIFICATION OF THE BACK COVER ASSEMBLY WITH BATTERY
2.5.1. The battery component is required to be classified under CTH 8507 by operation of Note 2(a) to Section XVI, in priority to any GRI 3(b) essential-character exercise.
2.5.1.1. The Applicant, at para 15 of its Statement of Facts, itself concedes that “the lithium-ion battery alone falls under 8507.” Having made this concession, the Applicant seeks to avoid its consequence by characterising the entire eleven-component assembly as a ‘composite good’ under GRI 3(b), the essential character of which is said to be structural rather than that of a battery. This approach cannot be accepted, for the following independent reasons.
2.5.1.2. First, and most directly, the General Explanatory Note to Section XVI itself — which is the WCO’s own commentary on the operation of Note 2(a) — gives an enumerated list of part that are goods “in all cases” classified in their own heading, “even if specially designed to work as part of a specific machine,” notwithstanding that they may also be capable of being viewed as a component of some larger assembly. Item (10) of that list is:
“Electric accumulators assembled into battery packs (heading 85.07).”
This is not a general principle applied to the facts by way of analogy — it is the precise fact pattern (a battery, specially designed for and assembled into a specific device) that the WCO Explanatory Note itself selects as a worked example of Note 2(a)’s operation. It leaves no room for a GRI 3(b) essential-character exercise to redirect a battery-containing assembly into heading 8473 merely because the battery has been physically integrated with structural/housing components. If GRI 3(b) essential-character reasoning could override this express example, Note 2(a)’s “in all cases” language would be reduced to a dead letter, since any OEM could bundle a separately-headed component (a battery, a motor, a populated PCB) with brackets/covers and claim essential character to redirect it into a general parts heading of its choosing. This precise methodology — sequential, mandatory application of Note 2(a) ahead of Note 2(b)/(c) or GRI 3 — has also been affirmed by the Customs Authority for Advance Rulings in its ruling on classification of lithium-ion cell inputs (cathode-coated foil, anode-coated foil, separator film and LC breaker), where the Authority held that Note 2(a) is to be examined first, and Note 2(b) is reached “‘only in cases where such parts cannot be classified as per Section Note 2(a).”
2.5.1.3. Second, the Explanatory Note to heading 85.07 itself, correctly read, supports classification of the assembly (or at least its battery-proximate portion) under 8507 rather than assisting the Applicant’s case. The Note expressly states that battery packs are covered by heading 8507 “whether or not they include any ancillary components… such as electrical connectors, temperature control devices…, circuit protection devices, and protective housings,” and further that such packs “are classified in this heading even if they are designed for use with a specific device.” This directly addresses — and rejects — the Applicant’s central premise, namely that integration with device- specific structural components (middle frame, lens fittings, bracket, etc.) takes the assembly out of 8507. The same Note additionally records, under its ‘Parts’ heading, that parts of accumulators expressly include “containers and covers” — confirming that even the word ‘cover’, in the context of a battery/accumulator, is already accounted for within heading 8507’s own scope, and need not be sought elsewhere.
2.5.2. Independently, the essential-character claim advanced by the Applicant is, in any event, unsupported by evidence.
2.5.2.1. Even assuming, without conceding, that GRI 3(b) were reached, essential character is a factual determination ordinarily assessed with reference to value, weight/bulk, and functional role of each constituent — none of which has been placed on record. The application does not furnish a component-wise value or weight break-up of the eleven items forming the assembly. Given that lithium-ion cells are frequently the highest-value and highest-weight constituent of such assemblies, an unsupported assertion that the “essential character” is structural cannot be accepted without such data.
2.5.3. Additionally, the heading text of CTH 8473 itself also excludes “covers… and the like,” which is a GRI-1 bar that the application does not address.
Exhibit 2: Photograph of the finished exterior back cover (realme-branded), as annexed by the Applicant, illustrating the external appearance of the article that gives the assembly its trade description of ‘back cover assembly’.
2.5.3.1, Heading 8473 excludes from its scope, by its own words, “covers, carrying cases and the like.” This is not a matter of essential-character weighing under GRI 3 ~ it is textual, and GRI 1 requires classification to first be tested against the terms of the heading itself. This is reinforced at the level of the Explanatory Notes: the Explanatory Note to heading 84.73 records, in terms, that
“the heading excludes covers, carrying cases and felt pads; these are classified in their appropriate headings.”
2.5.4. PART IV: SUMMARY OF ISSUES AND COMMENTS
| S.No. | Issue | Applicant’s Position | Commissionerate’s Comments | Recommendation |
|---|---|---|---|---|
| 1 | Classification of the Back Cover Assembly with Battery (as a composite article) | CTH 8473 (parts of ADP machine of heading 8471), by treating the assembly as a composite good under GRI 3(b), essential character being the structural/housing function | Section XVI Note 2(a), as illustrated by item (10) of the General Explanatory Note to Section XVI (“electric accumulators assembled into battery packs”), mandates that the lithium-ion battery be classified under CTH 8507 “in all cases,” in priority to any essential-character exercise under GRI 3(b); independently, no component-wise value/weight break-up has been furnished to support the Applicant’s essential-character claim; additionally, heading 8473, both by its own text and by its Explanatory Note, excludes “covers, carrying cases and the like/felt pads” | Not agreed as proposed. Entire assembly classified under CTH 8507—see Part V, para 14.4 |
2.5.5. PART V: REPLY OF THE JURISDICTIONAL COMMISSIONERATE
2.5.5.1. Maintainability: The application is maintainable. The Applicant holds a valid IEC, the proposed import is to take place within the jurisdiction of this Commissionerate (ACC Import, New Delhi), and the question raised is a genuine question of classification under Section 28H(2)(a) of the Customs Act, 1962.
2.5.5.2. Classification framework: This Commissionerate agrees, in principle, with the sequential framework of GRI 1 read with Section XVI Note 2(a)(c) as the governing methodology, but does not agree with the Applicant’s application of that framework to the facts.
2.5.5.3. On the proposed classification (CTH 8473): This Commissionerate does not concur with the Applicant’s proposed classification of the entire back cover assembly with battery under CTH 8473. For the reasons at Part III above — namely (a) the mandatory, sequentially-prior operation of Section XVI Note 2(a), which requires the lithium-ion battery (a good specifically and separately covered by CTH 8507) to be classified under 8507 “in all cases,” ahead of any GRI 3(b) essential- character exercise; (b) the absence of any component-wise value or weight break-up to support the Applicant’s essential-character claim; and (c) additionally, the express “covers… and the like” exclusion in the text of heading 8473 itself — this Commissionerate is of the considered view that the classification sought is not sustainable as framed.
2.5.5.4. Final classification: This Commissionerate concludes that the back cover assembly with battery, as presented, is classifiable in its entirety under CTH 8507, and not under CTH 8473 as proposed by the Applicant. CTH 8473 stands excluded, at the threshold, principally by the mandatory and sequentially-prior operation of Note 2(a) to Section XVI, which requires the lithium- . ion battery — a good specifically and separately covered by CTH 8507 —to be classified thereunder “in all cases,” ahead of any GRI 3(b) essential-character exercise; and, additionally and independently, by the express textual exclusion of “covers, carrying cases and the like” from the heading text of 8473 itself and its Explanatory Note. With CTH 8473 thus excluded at the threshold, and the assembly being a composite good for GRI 3(b) purposes, its essential character is that of the lithium-ion battery — the constituent occupying the substantial majority of the assembly’s internal area and value (Exhibit | refers), and performing its indispensable power-supply function — with the remaining components (back cover, middle frame, lens fitments, bracket, foam sheets, conductive cloth/pads, etc.) serving only as the ancillary structural housing that protects and retains the battery in position. This is squarely consistent with the Explanatory Note to heading 85.07, which confirms that battery packs remain classifiable under 8507 “whether or not they include any ancillary components… such as… protective housings,” and that they are so classified “even if they are designed for use with a specific device.” CTH 8507 is accordingly the final classification recommended by this Commissionerate for the assembly as a whole. 3s Record of Personal hearing: The Authorized Representative of the applicant appeared for the personal hearing conducted in virtual mode on 15.07.2026 and reiterated the submissions previously furnished in the application. No Authorized Representative appeared on behalf of the Department at the time of the personal hearing.
4. Additional Submission made by the applicant:
4.1. The comments received from the jurisdictional port Commissionerate in r/o the instant application was forwarded to the applicant. In response, the applicant vide email dated 17.08.2026 has submitted detailed rebuttal addressing the observations/comments raised by the Port Authority, which is reproduced as under: The concerned Commissionerate has observed that under Part II, Para 7(a),that “(a) Text of Heading 8473: “Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 8469 to 8472.” The exclusion of “covers, carrying cases and the like” is part of the statutory heading text itself and is therefore a GRI-1- level bar, before any GRI 2/3 essential-character analysis.”.
4.2. At the outset, the Applicant respectfully submits that the said observation requires reconsideration in light ,The exclusion clause of Heading 8473 targets discrete protective sleeves, silicone cases and portable storage pouches imported separately, whose sole function is superficial protection without structural mounting capacity. The subject “back cover assembly with battery of tablet PC” is not a simple protective casing. It is an integrated chassis framework equipped with mounting slots for cameras, heat dissipation structures and dedicated battery compartments, whose core function is to accommodate and fix all electronic components of the tablet PC. Dust/impact protection is only a secondary incidental function, which places the goods outside the scope of excluded simple protective covers.
4.3. Further, the Commissionerate has observed under part I] para 7(b)Note 2(a) to Section XVI: “Parts which are goods included in any of the headings of Chapter 84 or 85 (other than headings 84.09, 84.31, 84.48, 84.66, 84.73, 84.87, 85.03, 85.22, 85.29, 85.38 or 85.48) are in all cases to be classified in their respective headings.” Heading 8473 is itself among the headings excluded from this list — confirming that 8473 is a residual parts heading which is reached only where Note 2(a) does not independently place the article in a specific heading of Chapter 84/85. Heading 8507 (electric accumulators, including lithium-ion) is not among the excluded headings, and a lithium-ion battery is a specifically named good of that heading.
4.4. In response to the aforesaid observation of the Commissionerate, the Applica espectfully submit Firstly, the lithium-ion battery constitutes merely one component of the goods dude reviews in this case. The determination of the correct HS Code necessitates a holistic consideration of all constituent parts, requiring a comprehensive examination and evaluation of the entire assembly. Secondly, the ‘complete article’ into which the subject goods are to be incorporated is a complete tablet computer. Under General Rule 2(a) of Class XVI, the governing logic is that ‘parts are to be classified separately only if they themselves constitute a complete article falling within a specific heading of this class.’ The core prerequisite for this is that the independent item must be capable of performing its intended function autonomously and be capable of being marketed independently. The lithium-ion cells in question are incapable of standalone use. Once detached from the back cover assembly, middle frame, fixation structures, and thermal management accessories, they cannot be assembled into a tablet computer. Consequently, they do not qualify as a ‘complete article’ under General Rule 2(a).
4.5. Furthermore, the Commissionerate has observed under part II para 7(f) General Explanatory Note to Section XVI, Part (II) — “Parts” [commentary on Section Note 2], HSN Explanatory Notes, 2022 (7th) Edition, Vol. 4 (as paginated in the departmental copy, at the General Notes to Section XVI immediately preceding Chapter 84): after stating that parts which “in themselves constitute an article covered by a heading of this Section (other than headings 84.87 and 85.48)… are in all cases classified in their own appropriate heading even if specially designed to work as part of a specific machine,” the Note gives an enumerated list of examples. Item (10) on that list reads:”(10) Electric accumulators assembled into battery packs (heading 85.07).”
4.6. Further, the Applicant respectfully submits that (10) Electric accumulators assembled into battery packs (heading 85.07).The “battery pack” referred to in the WCO example has two typical forms. Form 1: Standardized replaceable battery modules circulated as independent commodities. Form 2: Integrated battery packs only fitted with battery-specific auxiliary parts, without any device-wide structural frames. The “battery pack” referred to in the WCO example: The battery cell is the primary subject, and the casing is a minor accessory attached to the battery. The subject tablet rear cover assembly in this case: The tablet’s integral middle frame and rear cover form the main body, with the lithium-ion cell merely embedded inside the device chassis. The integral chassis carries all core tablet components including display, mainboard, camera and speaker, and its structural function is entirely independent of the battery’s power storage demand, so it falls outside the scope regulated by General Explanatory Note to Section XVI, Part (II) (Section Note 2) Item (10).
4.7. Additionally ongoing the Commissionerate has observed under part II para 7(g) Explanatory Note to heading 84.73: in addition to the exclusion in the heading text itself, the Explanatory Note states in terms: “the heading excludes covers, carrying cases and felt pads; these are classified in their appropriate headings.”
4.8. In addition, it is respectfully submitted that The exclusion clause of Heading 8473 targets discrete protective sleeves, silicone cases and portable storage pouches imported separately, whose sole function is superficial protection without structural mounting capacity. The subject “back cover assembly” is not a simple protective casing. It is an integrated chassis framework equipped with mounting slots for cameras, heat dissipation structures and dedicated battery compartments, whose core function is to accommodate and fix all electronic components of the tablet PC. Dust/impact protection is only a secondary incidental function, which places the goods outside the scope of excluded simple protective covers.
4.9, Further, the Commissionerate has observed under part II para 7(h) Explanatory Note to heading 85.07: the Note states: “Accumulators containing one or more cells and the circuitry to interconnect the cells amongst themselves, often referred to as ‘battery packs’, are covered by this heading, whether or not they include any ancillary components which contribute to the accumulator’s function of storing and supplying energy, or protect it from damage, such as electrical connectors, temperature control devices (e.g., thermistors), circuit protection devices, and protective housings. They are classified in this heading even if they are designed for use with a specific device.” The same Note further records, under ‘Parts,’ that the heading “also covers parts of accumulators, ¢.g., containers and covers.”
4.10. Accordingly, the Applicant respectfully submits that the “protective housings” referenced in the 8507 commentaries are mini casings exclusively attached to the battery itself for energy storage and safety protection. The back cover and middle frame of the subject goods constitute the main chassis framework of the entire tablet PC, designed to hold and mount all internal components including PCB, display, speakers, cameras and the battery. They serve the tablet’s overall structural integrity rather than merely protecting the battery.
4.11. Further, the Commissionerate has observed under part III para 10 First, and most directly, the General Explanatory Note to Section XVI itself — which is the WCO’s own commentary on the operation of Note 2(a) — gives an enumerated list of parts that are goods “in all cases” classified in their own heading, “even if specially designed to work as part of a specific machine,” notwithstanding that they may also be capable of being viewed as a component of some larger assembly. Item (10) of that list is: “Electric accumulators assembled into battery packs (heading 85.07).” This is not a general principle applied to the facts by way of analogy — it is the precise fact pattern (a battery, specially designed for and assembled into a specific device) that the WCO Explanatory Note itself selects as a worked example of Note 2(a)’s operation. It leaves no room for a GRI 3(b) essential-character exercise to redirect a battery-containing assembly into heading 8473 merely because the battery has been physically integrated with structural/housing components. If GRI 3(b) essential-character reasoning could override this express example, note 2(a)’s “in all cases” language would be reduced to a dead letter, since any OEM could bundle a separately headed component (a battery, a motor, a populated PCB) with brackets/covers and claim essential character to redirect it into a general parts heading of its choosing. This precise methodology — sequential, mandatory application of Note 2(a) ahead of Note 2(b)/(c) or GRI 3 — has also been affirmed by the Customs Authority for Advance Rulings in its ruling on classification of lithium-ion cell inputs (cathode-coated foil, anode-coated foil, separator film and LC breaker), where the Authority held that Note 2(a) is to be examined first, and Note 2(b) is reached “only in cases where such parts cannot be classified as per Section Note 2(a).”
4.12. In response to the aforesaid observation of the Commissionerate, the Applicant respectfully submit that firstly, the lithium-ion battery constitutes merely one component of the goods under review in this case. The determination of the correct HS Code necessitates a holistic consideration of all constituent parts, requiring a comprehensive examination and evaluation of the entire assembly. Secondly, the ‘complete article’ into which the subject goods are to be incorporated is a complete tablet computer. Under General Rule 2(a) of Class XVI, the governing logic is that ‘parts are to be classified separately only if they themselves constitute a complete article falling within a specific heading of this class.’ The core prerequisite for this is that the independent item must be capable of performing its intended function autonomously and be capable of being marketed independently. The lithium-ion cells in question are incapable of standalone use. Once detached from the back cover assembly, middle frame, fixation structures, and thermal management accessories, they cannot be assembled into a tablet computer. Consequently, they do not qualify as a ‘complete article’ under General Rule 2(a).
4.13. Further, the Commissionerate has observed under part II] para 11 Second, the Explanatory Note to heading 85.07 itself, correctly read, supports classification of the assembly (or at least its battery- proximate portion) under 8507 rather than assisting the Applicant’s case. The Note expressly states that battery packs are covered by heading 8507 “whether or not they include any ancillary components… such as electrical connectors, temperature control devices…, circuit protection devices, and protective housings,” and further that such packs “are classified in this heading even if they are designed for use with a specific device.” This directly addresses — and rejects — the Applicant’s central premise, namely that integration with device-specific structural components (middle frame, lens fittings, bracket, etc.) takes the assembly out of 8507. The same Note additionally records, under its ‘Parts’ heading, that parts of accumulators expressly include “containers and covers” — confirming that even the word ‘cover’, in the context of a battery/accumulator, is already accounted for within heading 8507’s own scope and need not be sought elsewhere.
4.14. In response to the aforesaid observation of the Commissionerate, the Applicant respectfully submit that The “protective housings” referenced in the 8507 commentaries are mini casings exclusively attached to the battery itself for energy storage and safety protection. The back cover and middle frame of the subject goods constitute the main chassis framework of the entire tablet PC, designed to hold and mount all internal components including PCB, display, speakers, cameras and the battery serve the tablet’s overall structural integrity rather than merely protecting the battery.
4.15. Further, the Commissionerate has observed under part II] para 13 Heading 8473 excludes from its scope, by its own words, “covers, carrying cases and the like.” This is not a matter of essential- : character weighing under GRI 3 ~ it is textual, and GRI 1 requires classification to first be tested against the terms of the heading itself. This is reinforced at the level of the Explanatory Notes: the Explanatory Note to heading 84.73 records, in terms, that “the heading excludes covers, carrying cases and felt pads; these are classified in their appropriate headings.”
4.16. In response to the aforesaid observation of the Commissionerate, the Applicant respectfully submit that the exclusion clause of Heading 8473 targets discrete protective sleeves, silicone cases and portable storage pouches imported separately, whose sole function is superficial protection without structural mounting capacity. The subject “back cover assembly” is not a simple protective casing. It is an integrated chassis framework equipped with mounting slots for cameras, heat dissipation structures and dedicated battery compartments, whose core function is to accommodate and fix all electronic components of the tablet PC. Dust/impact protection is only a secondary incidental function, which places the goods outside the scope of excluded simple protective covers.
4.17. Further, the Commissionerate has observed under part II] para 14.3 On the proposed classification (CTH 8473): This Commissionerate does not concur with the Applicant’s proposed classification of the entire back cover assembly with battery under CTH 8473. For the reasons at Part II] above — namely (a) the mandatory, sequentially-prior operation of Section XVI Note 2(a), which requires the lithium-ion battery (a good specifically and separately covered by CTH 8507) to be classified under 8507 “in all cases,” ahead of any GRI 3(b) essential-character exercise; (b) the absence of any component-wise value or weight break-up to support the Applicant’s essential-character claim; and (c) additionally, the express “covers… and the like” exclusion in the text of heading 8473 itself — this Commissionerate is of the considered view that the classification sought is not sustainable as framed.
4.18. Therefore, the Applicant respectfully submits that All stages including the development, design, manufacturing and importation of the complete assembly are solely oriented to the assembly of finished tablet PCs. The lithium-ion battery is merely an embedded auxiliary component to meet the power supply demand of tablets. This assembly is never circulated, sold or replaced as an independent battery product. The intrinsic nature of the goods is a structural component for tablet PCs, instead of an electric accumulator pack. Sequence
I) Step 1 – GRI 1: Complete tablet PCs are classified under Heading 8471. The subject goods are composite parts exclusively for tablet PCs, so Heading 8473 shall be reviewed on a priority basis
II) Step 2 — Verify the exclusion clause under Heading 8473: The subject goods are not standalone protective sleeves or simple outer covers, but an integrated load-bearing chassis, thus falling outside the scope of such exclusion.
III) Step 3 — Application of Section XVI Notes 2: First, examine Note 2(a). A prerequisite for the application of Note 2(a) is that the component itself is a standalone standard part capable of independent commercial circulation and full independent operation. The embedded lithium-ion cell in this case cannot be separately assembled or used without the middle frame, rear cover and positioning structures of the assembly, so the application of Note 2(a) is ruled out. Since Note 2(a) is inapplicable, we proceed sequentially to apply Note 2(b). The subject goods are a composite of multiple electronic components without separable standalone functional standard parts, and are specially manufactured for matching tablet PCs, which satisfies the regulatory scenario of Note 2(b).In conclusion, the essential character of the subject back cover assembly with embedded battery for tablet PCs is that of a dedicated structural component for automatic data processing (ADP) machines (tablet computers), and the goods shall be classified under Customs Tariff Heading 8473 30 99.
5. Discussion, Findings & Conclusion:
5. Having examined the CAAR-1 application, the comments received from the jurisdictional Customs Commissionerate, rebuttal filed by the applicant, the record of personal hearing held on 15.07.2026, and the applicable legal framework, | 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 goods on the basis of the information on record.
Product Description:
5.1. The applicant describes the goods as a “back cover assembly with battery”, and in the covering letter as a “Battery Integrated Rear Cover” of a tablet PC. The product, per the technical data sheet mentioned in the application, comprises eleven (11) distinct components, namely: (i) middle frame; (ii) camera lens – 2 pcs; (iii) flash lens; (iv) conductive cloth – 3 pcs; (v) thermal conductive pad – 3 pcs; (vi) plastic bracket; (vii) water-proof label; (viii) plastic sleeve for power key; (ix) self-adhesive foam sheet – 4 pcs; (x) lithium-ion battery – 1 pc; and (xi) back cover – 1 pc. The applicant has furnished drawing of the goods, together with a table introduced by the applicant under the description “the tablet PC components”. Table submitted by the applicant has been reproduced below:
| No. | Description | Unit | Quantity |
|---|---|---|---|
| 1 | Middle Frame | PCS | 1 |
| 2 | Camera Lens | PCS | 2 |
| 3 | Flash Lens | PCS | 1 |
| 4 | Conductive Cloth | PCS | 3 |
| 5 | Thermal Conductive Pad | PCS | 3 |
| 6 | Plastic Bracket | PCS | 1 |
| 7 | Water-Proof Label | PCS | 1 |
| 8 | Plastic Sleeve for Power Key | PCS | 1 |
| 9 | Self-Adhesive Foam Sheet | PCS | 4 |
| 10 | Lithium-Ion Battery | PCS | 1 |
| 11 | Back Cover | PCS | 1 |
Functions:
A. Provide functions of structural accommodation and fixation for components such as PCBs, speakers, display screen, battery, and cameras, etc. of the tablet PCs;
B. Protect components from external impacts and dust contamination.
C. Power supply function.
D. Heat dissipation function.
5.2.The applicant has not disclosed the value or the weight of the individual items. The applicant has submitted that the assembly is incapable of independent commercial use and becomes functional only upon installation in the tablet computer together with other components such as the motherboard, display assembly, speaker modules and camera modules. The applicant has further submitted that the assembly cannot itself perform any automatic data processing function but merely forms one constituent part of the finished tablet and that it is also proposed to be imported to replace damaged tablet PCs of consumers at after-sales service stores.
Question for determination:
5.2. The issue before me is to determination of the classification of “Back cover assembly with battery of Tablet PCs” under the First Schedule to the Customs Tariff Act, 1975 — in particular, whether the goods are classifiable under Customs Tariff Item 8473 30 99, as claimed by the applicant or under CTH 8507 as contended by the jurisdictional Commissionerate or elsewhere.
Legal framework and competing headings:
5.4. The applicant, in its application, has submitted that the subject goods are described as “Back Cover assembly with Battery of the Tablet PCs”. The Board, vide Circular No. 20/2013-Customs dated 14.05.2013, examined the classification of products commercially known as “Tablet Computers” under the competing headings 8517 and 8471. The Board accordingly decided that machines commercially referred to as “Tablet Computers” are more appropriately classifiable in heading 8471, sub-heading 8471 30, by application of Rule 1 of the General Rules for Interpretation read with Note 3 to Section XVI and the Chapter 84 definition, and Rule 6, and recorded that this decision is consistent with the decision of the Harmonized System Committee of the World Customs Organization.
5.5. The competing headings in the present matter are heading 8471 (automatic data processing machines), heading 8473 (parts and accessories of the machines of headings 8470 to 8472) and heading 8507 (electric accumulators). The goods, as presented, do not constitute a complete or substantially complete automatic data processing machine — they possess neither a central processing unit, nor a display, nor an input unit — and are therefore not classifiable under heading 8471. Accordingly, the issue for determination essentially lies between heading 8473 and heading 8507. Therefore, the competing headings 8473 and 8507 are examined further.
Scope of Heading 8473:
5.7, The heading covers parts and accessories which are designed for use with the machines covered under headings 8470 to 8472. Since the tablet PC is classifiable under heading 8471, a part of such tablet PC may, in appropriate circumstances, fall under heading 8473. Heading 8473 reads: “Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 8470 to 8472. “Relevant Portion of Heading 8473 has been reproduced below:
| 8473 | PARTS AND ACCESSORIES (OTHER THAN COVERS, CARRYING CASES AND THE LIKE) SUITABLE FOR USE SOLELY OR PRINCIPALLY WITH MACHINES OF HEADINGS 8470 TO 8472 | |
| 8473 30 | – | Parts and accessories of the machines of heading 8471: |
| 8473 30 10 | — | Microprocessors |
| 8473 30 20 | — | Motherboards |
| 8473 30 30 | — | Other mounted printed circuit boards |
| 8473 30 40 | — | Head stack |
| 8473 30 | — | Other : |
| 8473 30 91 | — | Network access controllers |
| 8473 30 92 | — | Graphic and intelligence based script technology (GIST) cards for multilingual computers |
| 8473 30 99 | — | Other |
5.8. However, heading 8473 does not cover every article merely because it is used with a machine of heading 8471. The goods must first satisfy the terms of the heading and the relevant Section and Chapter Notes.
5.8.1 Heading 8473 is a heading for parts. Heading 8471 is in Section XVI of the Tariff, and Section XVI has its own Note – Note 2 – which lays down how parts of machines are to be classified.
5.8.2. Relevant portion of Note 2 to Section XVI has been reproduced below:
“2.– Subject to Note 1 to this Section, Note 1 to Chapter 84 and Note 1 to Chapter 85, parts of machines (not being parts of the articles of heading 84.84, 85.44, 85.45, 85.46 or 85.47) are to be classified according to the following rules:
(a) Parts which are goods included in any of the headings of Chapter 84 or 85 (other than headings 84.09, 84.31, 84.48, 84.66, 84.73, 84.87, 85.03, 85.22, 85.29, 85.38 and 85.48) are in all cases to be classified in their respective headings.
(b) Other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading (including a machine of heading 84.79 or 85.43) are to be classified with the machines of that kind or in heading 84.09, 84.31, 84.48, 84.66, 84.73, 85.03, 85.22, 85.29 or 85.38 as appropriate. …
(c) All other parts are to be classified in heading 84.09, 84.31, 84.48, 84.66, 84. 73, 85.03, 85.22, 85.29 or 85.38 as appropriate or, failing that, in heading 84.87 or 85.48.”
5.8.3. Note 2 to Section XVI provides the manner in which parts of machines are to be classified. Under Note 2(a), parts which are themselves goods covered under a heading of Chapter 84 or 85 are to be classified under their respective headings. Under Note 2(b), other parts which are suitable for use solely or principally with a particular machine are to be classified with that machine or under the specified parts headings.
5.8.4. It is therefore necessary to first examine Note 2(a). Only when the goods are not covered by Note 2(a) can Note 2(b) be considered. Heading 8473 is one of the headings specifically mentioned in Note 2(a) as an exception.
5.8.5. In view of the foregoing, it is evident that Note 2(a) to Section XVI establishes a specific rule of classification for parts of machines which are, in themselves, goods covered by a specific heading of Chapter 84 or Chapter 85. Such goods are required to be classified in their respective headings, irrespective of the fact that they may also be suitable for use as parts of another machine. Heading 8473 is itself among the headings excluded from this list- confirming that 8473 is a residual parts heading which is reached only where Note 2(a) does not independently place the article in a specific heading of Chapter 84/85.
5.8.6. In Collector of Central Excise v. Delton Cables Lid., 2005 (181) E.L.T. 373 (S.C.), the Supreme Court held that Note 2(b) applies only where the goods are not specifically classifiable in their own heading under Note 2(a). One cannot start at clause (b).
5.9. Note 3 to Section XVI provides that “Unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole and other machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function”. The underlying principle of this Note is that, where different components or functional elements are combined into a single imported article, classification is to be determined by identifying the function which gives the composite article its essential or principal character, rather than merely by identifying the presence of one or more individual components having separate or ancillary functions.
5.9.1. The applicant has stated that the subject assembly performs four functions, namely, (a) structural accommodation and fixation of components such as the PCB, speakers, display screen, battery and cameras; (b) protection of the components from external impact and dust; (c) power supply; and (d) heat dissipation. I have examined these functions individually to determine the nature of the imported goods. The applicant has stated that the assembly provides structural accommodation and fixation for various components, including the battery. Thus, the battery is itself one of the components which is housed and secured within the back cover and middle frame. The photogram of back cover assembly produced by the applicant has been reproduced below:
5.9.2. On perusal of the application and the photograph, it can be made out that the function of power supply is performed by the lithium-ion battery incorporated in the assembly and not by the back cover or middle frame, Once the battery is considered separately, the back cover and middle frame only provide support, protection and housing. The function of storing and supplying electrical energy is performed entirely by the lithium-ion battery. This indicates that the structural portion of the assembly performs the function of housing and protecting the battery along with the other components of the tablet PC.
5.9.3. The thermal conductive pads and conductive cloth are provided around the battery. Therefore, the heat-management arrangement is also associated with the battery and its operation. This function, by itself, does not give the back cover assembly an independent electrical character.
5.9.4. Further, the photograph (Figure 2) of the assembly furnished by the applicant shows that the lithium-ion battery occupies a substantial portion of the internal space of the assembly. This also supports the finding that the battery is a significant component of the imported goods.
5.10. Heading 8473 does not cover every article merely because it is used with, or is suitable for use with, a machine of heading 8471. The goods must, in the first instance, satisfy the terms of heading 8473 itself, read together with the relevant Section and Chapter Notes. Significantly, the heading expressly excludes “covers, carrying cases and the like”. The Explanatory Note to heading 84.73 says the same. The relevant portion of the explanatory Notes to the heading 84.73 has been reproduced below:
“But the hog excludes covers, cag cases and felt pads; these are classified in their appropriate headings. It also excludes articles oh Hg and (e.g., Leg aophed and tables) whether or not peel? designed for office use (heading 94.03). However, stands for machines of headings 84.70 to 84.72 not normally usable except with the machines in question, remain in this heading.”
The Explanatory Note to heading 84.73, which also excludes covers, carrying cases and felt pads and states that such articles are to be classified in their appropriate headings.
5.10.1. The applicant, in its rebuttal, has submitted that the expression “covers, carrying cases and the like” refers mainly to detachable protective articles such as sleeves, silicone cases and storage pouches. It has contended that the subject goods are different, as they form an integral structural part of the tablet PC and contain mounting provisions, heat-dissipation structures and a battery compartment. The applicant has therefore submitted that the subject goods should not be treated as an ordinary or detachable cover.
5.10.2. In the present case, the subject goods are described by the applicant itself as a “Back Cover Assembly with Battery” and “Battery Integrated Rear Cover”. The structural portion of the assembly primarily provides housing, fixation and protection to the internal components, including the battery. The incorporation of the battery, which occupies a substantial portion of the assembly and performs the sole active electrical function, does not by itself make the back cover and middle frame a part or accessory of the tablet PC classifiable under heading 8473. Rather, the nature and essential character of the imported goods have to be determined with reference to their constituent components and the specific exclusions under heading 84.73.
5.10.3. Accordingly, | find that the subject goods, to the extent they constitute the back cover/middle frame and associated housing components, are covered by the exclusion of “covers, carrying cases and the like” under heading 8473 and cannot be classified thereunder merely on the ground that they are designed for use with a tablet PC falling under heading 8471. The lithium-ion battery incorporated therein is required to be examined separately in accordance with the applicable tariff provisions governing such batteries. Therefore, the subject “Back Cover Assembly with Battery of Tablet PCs” is not classifiable as a whole under heading 8473.
5.11. From the foregoing discussion, it is observed that the Back Cover Assembly with Battery of Tablet PCs is not classifiable under heading 8473 of the First Schedule to the Customs Tariff Act, 1975, Accordingly, it is necessary to examine the other competing tariff heading which may potentially cover the subject goods. Therefore, the relevant tariff headings, Section Notes, Chapter Notes and the Explanatory Notes are required to be examined in order to determine the appropriate classification of the subject goods. “ The General Explanatory Note to Section XVI relating to “Parts”, which further explains the manner in which parts of machines and apparatus are to be classified. The Relevant portion of General explanatory note has been reproduced below:
“PARTS
(Section Note 2)
In general, parts which are suitable for use solely or principally with particular machines or apparatus (including those of heading 84.79 or heading 85.43) or with a group of machines or apparatus falling in the same heading, are classified in the same heading as those machines or apparatus subject, of course, to the exclusions mentioned in Part (I) above. Renaraie headings are, however, provided for
(A) Parts of the engines of heading 84.07 or 84.08 (heading 84.09).
(B) Parts of the machinery of headings 84.25 to 84.30 (heading 84.31).
(C) Parts of the textile machines of headings 84.44 to 84.47 (heading 84.48).
(D) Parts of the machines of headings 84.56 to 84.65 (heading 84.66).
(E) Parts of the office machines of headings 84.70 to 84.72 (heading 84.73)……….
The above rules do not apply to parts which in themselves constitute an article covered by a heading of this Section (other than headings 84.87 and 85.48); these are in all cases classified in their own appropriate heading even if. pecially designed to work as part of a specific machine. This applies in particular to :
(1) Pumps and compressors (headings 84.13 and 84.14).
(2) Filtering machinery and apparatus of heading 84.21.
(3) ….. ……
(4) …… …….
(9) Electrical transformers and other machines and apparatus of heading 85.04. :
(10) Electric accumulators assembled into battery packs (heading 85.07)…….”
It states, in general, that parts suitable for use solely or principally with particular machines or apparatus are classified with those machines, subject to the specified exclusions. However, the Note specifically clarifies that this principle does not apply to parts which in themselves constitute an article covered by a heading of Section XVI. Such articles are to be classified in their own appropriate heading even when they are specially designed to work as part of a specific machine.
5.11.1. The General Explanatory Note gives several examples of such separately classifiable articles, including electric transformers of heading 8504, and, importantly for the present case, “electric accumulators assembled into battery packs (heading 8507)”. Thus, an electric accumulator does not lose its classification under heading 8507 merely because it is assembled into a battery pack or is specially designed for use in a particular machine.
5.11.2. The above principle is relevant to the present case. The lithium-ion battery incorporated in the subject back cover assembly is an electric accumulator specifically covered by heading 8507. The fact that it is assembled with the back cover, middle frame and other components and is specially designed for use in a tablet PC does not, by itself, make it a part classifiable under heading 8473.
5.11.3. Therefore, the General Explanatory Note to Section XVI supports the view that where a component is itself an article specifically covered by a heading of Section XVI, its classification is to be made under that specific heading, even if it is designed for use as a component of another machine.
In the present case, the specific coverage of the lithium-ion accumulator under heading 8507 has to be considered before resorting to the general parts heading 8473.
Scope of Heading 8507:
5.12. The Heading 8507 is for the “Electric accumulators, including separators therefor, whether or not rectangular (including square)”. The relevant portion of heading 8507 is reproduced below:
| 8507 | ELECTRIC ACCUMULATORS, INCLUDING SEPARATORS THEREFOR, WHETHER OR NOT RECTANGULAR (INCLUDING SQUARE) |
| 8507 10 00 | Lead-acid, of a kind used for starting piston engines |
| 8507 20 00 | Other lead-acid accumulators |
| 8507 30 00 | Nickel-cadmium |
| 8507 50 00 | Nickel-metal hydride |
| 8507 60 00 | Lithium-ion |
| 8507 80 00 | Other accumulators |
| 8507 90 | Parts: |
| 8507 90 10 | Accumulator cases made of hard rubber and separators |
| 8507 90 90 | Other |
5.12.1. An electric accumulator, in general, is a device which stores electrical energy by chemical means and returns it on discharge, the chemical action being reversible so that the device can be charged again and re-used.
5.13. The first question, therefore, is whether “back cover assembly with battery” can fall within the expression “electric accumulators” for the purposes of heading 8507. In this regard, Note 3 to Chapter 85 is of direct relevance. Note 3 to Chapter 85 reads as follows:
“3.— For the purposes of heading 85.07, the expression ‘electric accumulators’ includes those presented with ancillary components which contribute to the accumulator’s function of storing and supplying energy or protect it from damage, such as electrical connectors, temperature control devices (for example, thermistors) and circuit protection devices. They may also include a portion of the protective housing of the goods in which they are to be used.”
5.13.1. The Note specifically provides that, for the purposes of heading 85.07, the expression “electric accumulators” includes those presented with ancillary components which contribute to the accumulator’s function of storing and supplying energy or protect it from damage, and further provides that “They may also include a portion of the protective housing of the goods in which they are to be used.”
5.13.2. The language of Note 3 is significant because it expressly contemplates an accumulator being presented together with components other than the accumulator itself. Therefore, classification under heading 8507 is not confined to a bare battery or to a battery physically isolated from the equipment in which it is intended to be used. The Note specifically recognises that an accumulator may be presented with ancillary components having a functional relationship with the accumulator and may also include a portion of the protective housing of the host goods.
5.13.3. In the present case, the lithium-ion battery constitutes the electric accumulator. The other components of the assembly have to be examined in the light of the two categories expressly recognised in Note 3, namely, (i) ancillary components which protect the accumulator from damage or contribute to its functioning, and (ii) a portion of the protective housing of the goods in which the accumulator is to be used.
5.13.4. The thermal conductive pads, conductive cloth, self-adhesive foam sheets, plastic bracket and waterproof label are not unrelated articles merely assembled with the battery. Their placement and incorporation into the rear-cover assembly are connected with the securing, insulation, thermal management and protection of the battery. The thermal conductive pads and conductive cloth assist in managing heat and maintaining the appropriate operating environment around the battery, while the foam, bracket and waterproofing arrangements contribute to its secure positioning and protection. These functions have a direct nexus with the safe operation and protection of the accumulator.
5.13.5. Similarly, the middle frame and back cover constitute portions of the protective housing of the tablet PC in which the battery is intended to be used. The applicant has stated that the back cover provides safety to the battery and internal components, provides ingress protection and structural support, and protects the internal PCB, sub-components and the battery from dust, moisture and other foreign particles. It has further been stated that exposure of the PCB or battery to such particles may result in damage and malfunction of the device and that the back cover reduces the accumulation of dust on the battery terminals. These facts establish a direct protective relationship between the housing and the battery.
5.13.6. In this context, the fact that the back cover also protects other components of the tablet PC does not take it outside the scope of Note 3. The language of the Note does not prescribe that the protective housing must serve the accumulator exclusively. What is relevant is whether the housing presented with the accumulator forms a portion of the protective housing of the goods in which the accumulator is to be used and whether it provides protection to the accumulator. In the present case, both requirements are satisfied.
5.13.7. The functional character of the assembly also supports this conclusion. The applicant has identified the functions of the assembly as including power supply, sucpara accommodation and fixation, protection from external impact and dust, and he; Se sipaty eh The power-supply we function is performed by the lithium-ion battery, while the remaining structural and thermal components . provide the physical environment necessary for the battery’s secure installation, protection and safe . operation. Thus, the various components are functionally interconnected and are not a mere collection of independent goods.
5.13.8. I therefore find that the components of the subject assembly can be appropriately placed within the scope of Note 3 to Chapter 85. The lithium-ion battery constitutes the accumulator; the thermal pads, conductive cloth, foam sheets, plastic bracket and waterproofing components constitute ancillary components contributing to the protection and safe functioning of the accumulator; and the middle frame, back cover and associated fittings constitute portions of the protective housing of the tablet PC which also protect the accumulator. The components therefore have the requisite functional nexus contemplated by Note 3.
5.13.9. Having arrived at the above finding, the application of Note 2 to Section XVI becomes relevant, Note 2(a) provides that parts which are goods included in any of the headings of Chapter 84 or 85, subject to the specified exclusions, are “in all cases” to be classified in their respective headings. Since the subject goods, as presented, are covered by heading 8507 read with Note 3 to Chapter 85, they are required to be classified in their respective heading under Note 2(a).
5.13.10. Further, the fact that the imported assembly is intended for incorporation into a tablet PC does not, by itself, override the specific treatment prescribed under Note 3 to Chapter 85. The relevant consideration is not merely whether the goods are principally used with a machine of heading 8471, but whether the goods are specifically covered by any heading of Chapter 84 or 85. In the present case, the assembly incorporates a lithium-ion electric accumulator along with protective and_ structural components associated with the accumulator.
5.13.11. I therefore find that the essential character and functional identity of the imported assembly, for purposes of the present classification exercise, are closely connected with the integrated electric accumulator and its protection. The assembly performs the functions of supplying electrical energy through the lithium-ion battery and providing the structural, thermal, and protective environment necessary for the safe operation of that battery. These are precisely the circumstances for which Note 3 to Chapter 85 provides an extended meaning to the expression “electric accumulators”.
5.13.12. Accordingly, on application of Rule 1 of the General Rules for the Interpretation of the Import Tariff, read with heading 8507 and Note 3 to Chapter 85, and having regard to Note 2(a) to Section XVI, I find that the subject “Battery Integrated Rear Cover/Back Cover Assembly with Battery” is appropriately classifiable under CTH 8507. The specific coverage of the goods under heading 8507, together with the express exclusion of covers, carrying cases and the like from heading 8473, rules out classification of the subject goods under CTH 8473 30 99.
5.14. The Port Commissionerate has opined that the back cover assembly with battery, as presented, is classifiable in its entirety under CTH 8507 and not under CTH 8473. It has submitted that Note 2(a) to Section XVI requires parts which are themselves goods covered by a heading of Chapter 84 or 85 to be classified in their respective headings and, therefore, the lithium-ion battery, being specifically covered under CTH 8507, merits classification thereunder. It has further submitted that CTH 8473 is independently excluded by the specific exclusion of “covers, carrying cases and the like” from the heading. The Port Commissionerate has also considered the imported goods as a composite good and stated that the lithium-ion battery imparts the essential character to the assembly, having regard to its substantial proportion in the assembly and its essential power-supply function, while the remaining components such as the back cover, middle frame, brackets, foam sheets and conductive materials primarily serve structural, protective and retaining purposes. Reliance has t placed on the Explanatory Notes to heading 85.07, which provide for classification battery packs under that heading even when they incorporate ancillary components such as protective housings or are designed for use with a specific device.
5.15. In view of the foregoing discussion, I find that the subject “Back Cover Assembly with Battery” cannot be classified under CTH 8473 merely on the ground that it is designed for use with a tablet PC classifiable under heading 8471. Heading 8473 is a general parts and accessories heading and expressly excludes “covers, carrying cases and the like”. More importantly, the lithium-ion battery incorporated in the assembly is itself an electric accumulator specifically covered by heading 8507, and Note 3 to Chapter 85 expressly permits an accumulator to be presented with ancillary components contributing to its function or protecting it from damage, as well as with a portion of the protective housing of the goods in which it is used. In the present case, the battery performs the essential active function of storing and supplying electrical energy, while the back cover, middle frame and associated components provide the structural, thermal and protective environment for the battery. Thus, the imported goods, in their condition as presented, are specifically covered under heading 8507 read with Note 3 to Chapter 85. Consequently, by virtue of Note 2(a) to Section XVI, which requires goods covered by a specific heading of Chapter 84 or 85 to be classified in their respective headings, resort to the more general parts heading 8473 is not warranted. The fact that the assembly is specially designed for incorporation into a tablet PC does not alter this conclusion. Accordingly, the subject Back Cover Assembly with Battery/Battery Integrated Rear Cover is appropriately classifiable in its entirety under CTH 8507, and not under CTH 8473 30 99 as claimed by the applicant.
5.16. Having placed the goods in heading 8507, sub-classification proceeds under Rule 6 of the GRI. The applicant, in its application, submitted that the accumulator in the subject assembly is a lithium-ion battery. Sub-heading 8507 60 covers lithium-ion accumulators. At the eight-digit level, the corresponding tariff item in the First Schedule is 8507 60 00, and there is no competing entry at that level.
6. In view of the foregoing discussion and findings
The product described as “back cover assembly with battery” of tablet PCs, merits classification under heading 8507 of the First Schedule to the Customs Tariff Act, 1975, and specifically under tariff item 8507 60 00.
I rule accordingly.
