Kitchen Exhaust Hoods Over 120 cm Classifiable Under CTH 8414 80 90: CAAR Mumbai

In re Halton India Private Limited (CAAR Mumbai)

Summary: The Customs Authority for Advance Rulings (CAAR), Mumbai reconsidered the customs classification of “Kitchen Exhaust Hoods with different Models” proposed to be imported by Halton India Private Limited following a remand by the Karnataka High Court. The Authority had originally classified the goods under Heading 8414 80, specifically CTH 8414 80 90. The applicant challenged that ruling before the Karnataka High Court in CSTA No. 12/2026. By order dated 06.08.2026, the High Court set aside the original ruling and remanded the matter for fresh consideration after permitting the applicant to furnish additional supporting material. The applicant thereafter submitted a detailed technical write-up showing that the kitchen exhaust hoods incorporate a factory-fitted “Capture Jet fan” as one of eleven components and argued that, since the hoods exceeded 1200 mm in length and incorporated a fan, they should be classified under CTH 8414 59 90 as “Other” fans.

On reconsideration, CAAR accepted the factual contention that the Capture Jet fan was an integral component of the imported kitchen hood. It nevertheless rejected the proposed classification under CTH 8414 59 90. Heading 8414 separately refers to “fans” and to “ventilating or recycling hoods incorporating a fan”. CAAR observed that this tariff language treats the two as distinct classes of goods. The WCO Explanatory Notes similarly organise Heading 84.14 into separate groups covering pumps and compressors, fans, and ventilating or recycling hoods incorporating a fan. The Authority therefore held that incorporation of a fan does not convert a complete ventilating or recycling hood into a “fan” for tariff purposes.

CAAR further noted that the Capture Jet fan was only one component of a substantially larger assembly comprising, among other things, an outer casing, exhaust and supply air connections with adjustment dampers, a light fixture, grease filtration equipment, grease collection tray and perforated front face. Viewed as a whole, the imported product retained the essential character of a hood rather than that of a fan. CTH 8414 60 00 specifically covers hoods having a maximum horizontal side not exceeding 120 cm. Since the subject kitchen exhaust hoods exceeded that dimensional limit, they could not fall under CTH 8414 60 00. However, exceeding 120 cm did not justify shifting them into the tariff entries applicable to fans. As no other specific tariff entry under Heading 8414 applied, CAAR held that the goods fell within the residual entry under CTH 8414 80, specifically Tariff Item 8414 80 90 — “Other”. Accordingly, notwithstanding the factual finding that the kitchen exhaust hoods incorporate an integral fan, CAAR maintained their classification under CTH 8414 80 90.

Cases Discussed

• Halton India Private Limited v. Customs Authority for Advance Rulings & Anr., 2026 LLBiz HC (KAR) 146 (Karnataka High Court), Customs Appeal No. 12 of 2026, decided on 06.08.2026 — The Karnataka High Court set aside CAAR/Mum/ARC/167/2025-26 dated 25.03.2026 and remanded the classification dispute for fresh consideration after permitting the applicant to furnish additional material; in the present ruling, CAAR reconsidered the matter pursuant to that remand and recorded the factual finding that the subject kitchen exhaust hoods incorporate an integral fan.

FULL TEXT OF THE ORDER OF CUSTOMS AUTHORITY OF ADVANCE RULING, MUMBAI

1. M/s. Halton India Private Limited (IEC No.: 0711006709) (“the Applicant”) an application (CAAR-1) for advance ruling in the Office of Secretary, Customs Authority for Advance Ruling (CAAR) Mumbai. The said application was received in the secretariat of the CAAR, Mumbai on 05.01.2026 along with its enclosures in terms of Section 28H (1) of the Customs Act, 1962 (hereinafter referred to as the ‘ Act also’), seeking advance ruling on the classification of “Kitchen Exhaust Hoods with different Models” proposed to be cleared from Bengaluru Customs.

1.2. Accordingly, Ruling No. CAAR/Mum/ARC/167/2025-26 dated 25.03.2026 (“the Original Ruling“) was passed by Customs Authority for Advance Ruling (CAAR) Mumbai. As per the said ruling, this Authority held that the subject goods merited classification under Heading 8414 80, more specifically under sub-heading 8414 8090 (“Other”).

1.3. Aggrieved by the said Original Ruling, the Applicant appealed before the Hon’ble High Court of Karnataka in CSTA No. 12/2026. By order dated 06.08.2026, the Hon’ble High Court set aside the said Original Ruling and remanded the matter to this Authority for fresh consideration, directing the Applicant to furnish supporting documents within 15 days, and directing this Authority to take into consideration the additional information provided by the applicant.

1.4. In compliance, the Applicant vide letter dated 17.08.2026. furnished additional technical write-up with respect to the Kitchen Exhaust Hoods. and reiterated the prayer that the goods be classified under CTH 8414 5990.

2.Additional Submission by the Applicant:

2.1. The technical write-up furnished with the letter dated 17.08.2026 contains a labelled component diagram of the hood, identifying eleven numbered parts, extracted below:

i. Outer casing — visible parts in stainless steel AISI 304

ii. Exhaust air connection and adjustment damper

iii.Supply air connection and adjustment damper (type MSM)

iv.Light fixture with electrical junction box

v. Capture JetTM nozzles

vi. KSA grease filter

vii. Grease collection tray / drain tap

viii. Personal supply air nozzles

ix. Capture JetTM fan

x. Capture JetTM fan air inlet plenum (option)

xi. Perforated front face

2.2. The Applicant has pointed out that component No. 9 is described as the “Capture Jet fan” is an integral part of the subject kitchen hoods and the hoods cannot perform their intended function of capturing and removing airborne contaminants without the operation of the fan.

2.3. The Applicant has further submitted that the kitchen exhaust hoods proposed to be imported are more than 1200 mm in length and are equipped with its proprietary “Capture Jet” fan system.

2.4. The Applicant has reiterated that the principal function of the subject kitchen exhaust hood is to capture, contain and remove airborne contaminants generated during cooking, including heat, smoke, grease particles, steam and odours and that the incorporated fan is an essential component in achieving this function.

2.5. The Applicant has therefore requested that the subject goods be classified under CTH 8414 59 90 —Other.

3. Discussion and Findings

3.1. On examination of the component diagram and the accompanying write-up placed on record, I find that the subject Kitchen Exhaust Hoods do incorporate a fan — identified in the manufacturer’s own literature as the “Capture Jet fan” as an integral, factory-fitted component of the kitchen hood assembly.

3.2. Heading 8414 covers, inter alia, “air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters…”. At the sub­heading level, the heading splits, at the single-dash level, into “(-) Fans” and “(-) Hoods having a maximum horizontal side not exceeding 120 cm.” The relevant tariff entries are extracted below for reference:

3.3. The text of Heading 8414 describes two distinct classes of goods, separated by a semi-colon: “…fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters…”. On a plain reading, “ventilating or recycling hoods incorporating a fan” is separately recognised as a description of goods, and distinct from “fans”. Further, the tariff structure places “Fans” and “Hoods having a maximum horizontal side not exceeding 120 cm” as separate single-dash categories. This indicates that a ventilating or recycling hood incorporating a fan is recognised as a distinct product category and is not to be treated as a “Fan” merely because a fan is incorporated in the hood.

3.4. This reading is confirmed by the WCO Explanatory Notes to Heading 84.14, which organise the heading into three groups — (A) Pumps and Compressors, (B) Fans, and (C) Ventilating or Recycling Hoods Incorporating a Fan, Whether or Not Fitted with Filters. Group (C) is described as including cooker hoods incorporating a fan for domestic or institutional use, as well as laboratory and industrial hoods incorporating a fan. Group (C) is a free-standing group; it is not presented as a sub-set of Group (B), and nothing in the Notes suggests that a hood, merely by reason of incorporating

3.5. This is reinforced by the General Explanatory Note to Group (B) itself, which excludes from that group fans _sfitted with elements additional to their motor or housing (such as large dust separating cones, filters, cooling or heating elements and heat exchangers) where such elements give the goods the character of a more complex machine of another heading (for example, air heaters, air-conditioning machines., dust extractors, and electric space heaters with built-in fans). The underlying principle — that a fan, once integrated into a larger, structurally complex assembly, takes on the character of that assembly rather than remaining classifiable as a mere fan — applies apart from the fact where the resulting assembly is itself an item separately named within the same Heading, namely a “ventilating or recycling hood.” On the Applicant’s own technical write-up, the Capture Jet fan is one of eleven listed components of the hood assembly, which additionally comprises an outer casing, exhaust and supply air connections with adjustment dampers, a light fixture, grease filtration (nozzles and KSA filter), a grease collection tray, and a perforated front face. The assembly, considered as a whole and as marketed, has the essential character of a hood, not of a fan.

3.6. It is also relevant that CTH 8414 60 specifically covers hoods having a maximum horizontal side not exceeding 120 cm. Thus, the specific entry is limited to hoods within that dimension. I have also considered the Applicant’s submission that, since the subject goods exceed 120 cm and incorporate a fan, they should be classified under CTH 8414 59 90 as “Other” fans. The fact that the subject goods exceed 120 cm does not, by itself, mean that they should be classified as “Fans” under CTH 8414 59 90. Rather, the goods continue to be identifiable as hoods and where the specific entry for hoods does not apply due to the dimensional limitation, classification should be considered under the appropriate residual entry.

3.7. Accordingly, while I accept, as a matter of fact and in compliance with the directions of the I-Ion’ble High Court, that the subject Kitchen Exhaust Hoods incorporate a fan, I hold that this finding does not, in law, alter their classification. The goods remain, in essential character, “ventilating or recycling hoods incorporating a fan”, and not “Fans”. As they exceed 120 cm in horizontal side/width, they fall outside the specific entry CTH 8414 60 00. Not being classifiable under any other specific single-dash, double-dash or triple-dash entry of the Heading, they merit classification under the residual entry CM 8414 80, more specifically CTH 8414 80 90 — “Other”.

Ruling

4.1. In compliance with the order dated 06.08.2026 of the Hon’ble High Court of Karnataka in CSTA No. 12/2026, I record the factual finding that the subject “Kitchen Exhaust Hoods (with different models)” incorporate a fan, as an integral component of the hood assembly.

4.2. I further hold, for the reasons recorded above, that this factual finding does not affect the classification of the goods, since “ventilating or recycling hoods incorporating a fan” constitute a class of goods separate from and coordinate with, “Fans” under Heading 8414.

4.3. Accordingly, I rule that “Kitchen Exhaust Hoods (with different models)” proposed to be imported by the Applicant, having a horizontal side/width exceeding 120 cm, merit classification under Heading 8414 and more specifically under sub-heading 8414 80, Tariff Item 8414 80 90 — “Other”, of the First Schedule to the Customs Tariff Act, 1975.

4.4. I rule accordingly.