PVC-Coated Polyester Fabric Classified Under HSN 3921 at 18% GST: Tamil Nadu AAR

In re SRF Limited (GST AAR Tamilnadu)

Summary: SRF Limited approached the Tamil Nadu Authority for Advance Ruling seeking classification and the applicable GST rate for double-sided PVC-coated polyester woven fabric supplied as rectangular sheets and rolls. The product is used for outdoor awnings and covers, protective machinery coverings, tents and seat covers. Its reported composition was 37% PVC, 32% polyester fabric and 31% other chemicals, including plasticisers, fillers and stabilisers. The applicant sought a ruling on whether the product fell under HSN 3921 or HSN 5903. The applicant submitted that the polyester woven base was entirely covered by PVC on both sides, with the coating visible to the naked eye, while the textile substrate served primarily as reinforcement. It argued that Section XI Note 1(h) and Chapter 59 Note 2(a)(3) of the Customs Tariff excluded such fully plastic-coated textile products from heading 5903. The applicant accordingly proposed classification in Chapter 39, particularly tariff items 39219022 and 39219029.

The Authority examined the samples, product characteristics, General Rules for Interpretation, relevant Section and Chapter Notes and the competing tariff headings. It found that the PVC layers concealed the woven texture, weave pattern and yarn structure, and that the coating was visible to the naked eye. As the textile was completely covered on both sides, the product fell within the specific exclusion from heading 5903. The Authority also observed that plastic-related components accounted for 68% of the product, compared with 32% textile content. On classification within Chapter 39, the Authority found that the flexible product, supplied in rectangular sheets or uncut rolls, was covered by heading 3921 rather than the other enumerated headings. Since the PVC coating was non-cellular and the product could be lacquered or unlacquered, it determined the applicable eight-digit classifications as HSN 39219022 for flexible lacquered sheets and HSN 39219029 for the other, non-lacquered form.

For GST rate purposes, the Authority applied serial number 122 of Schedule II to Notification No. 9/2025-Central Tax (Rate), dated 17 September 2025, which covers heading 3921. It ruled that the product attracts CGST at 9% and SGST at 9%, aggregating to 18%. Thus, the answer to classification under HSN 3921 was affirmative and the answer for HSN 5903 was negative. No named judicial precedent is expressly analysed in the supplied ruling.

FULL TEXT OF THE ORDER OF AUTHORITY FOR ADVANCE RULING, TAMILNADU

1. Any appeal against this Advance Ruling order shall lie before the Tamil Nadu State Appellate Authority for Advance Ruling, Chennai under Sub-Section (1) of Section 100 of CGST Act 2017/ TNGST Act 2017, within 30 days from the date on which the ruling sought to be appealed is communicated.

2. In. terms of Section 103(1) of the Act, Advance Ruling pronounced by the Authority under Chapter XVII of the Act shall be binding only-

a. On the applicant who had sought it in. respect of any matter referred to in sub-section (2) Section 97 for advance ruling.

b. On the concerned officer or the Jurisdictional Officer in respect of the applicant

3. In terms of Section 103(2) of the Act, this Advance Ruling shall be binding unless the law, facts or circumstances supporting the original advance ruling have changed.

4. Advance Ruling obtained by the applicant by fraud or suppression of material facts or misrepresentation, of facts, shall render such ruling to be void ab initio in accordance with Section 104 of the Act.

5. The provisions of both the Central Goods and Services Tax Act and the Tamil Nadu Goods and Services Tax Act (herein referred to as the Act) are the same except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the Central Goods and Services Tax Act would also mean a reference to the same provisions under the Tamil Nadu Goods and Services Tax Act.

M/s SRF Limited, having place of business at Building no. 1, Neduncheziyan Street, Manali, Chennai, Tamil Nadu-600068 (hereinafter called as the “Applicant”) has registered with GSTIN 33AAACS0206P1ZK under the Goods and Services Tax Act. They have filed this application for advance ruling under Section 97 of the CGST Act, 2017, and corresponding provisions under the Section 97 of TNGST Act, 2017. The Applicant has made a payment of application fees of Rs.10, 000/- under sub rule (1) of Rule 104 of CGST Rules, 2017 and TNGST Rules, 2017.

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

i. The Applicant is inter-alia engaged in the business of manufacturing and sale of double-sided Polyvinyl Chloride (hereinafter referred to as PVC’) coated fabric. The Applicant manufactures and sells the product in the form of Rectangular Sheets and rolls.

ii. The Double-sided PVC coated woven fabric (hereinafter referred to as the product’) is a polyester (woven) fabric which is fully coated with PVC on both sides. It is not a monofilament.

iii. The width of the product varies from 1.37 m to 3.35 m depending on the customer’s requirements and thickness of the coating. The product is well-suited for a range of applications, including Outdoor Awnings and Covers, Protective Machine/Equipment Coverings, Tents and Seat Covers.

iv. The approximate percentage composition of the individual components as present in the product (average of 600 gsm fabric) is as follows:

v. Test report evidencing the presence of a uniform PVC layer discernible to the naked eye on the surface of the product is submitted.

vi. The coating is not cellular plastic, and the product is neither metallised nor laminated, and may or may not be lacquered.

vii. The sole purpose of the textile fabric in the product is reinforcement for tensile and tear strength. The product does not undergo any surface treatment or printing. Further, the product can be manually bent around a cylinder of a diameter of 7mm, without any fracturing at a temperature between 15 degrees Celsius to 30 degrees Celsius.

3. Questions raised by the applicant:

The applicant has filed the present application for advance ruling seeking clarification on the following questions:

i. Whether the product is classifiable under Chapter Heading 3921?

ii. Whether the product is classifiable under Chapter Heading 5903?

iii. In case answer to (i) and (ii) are in negative, what is the HSN under which the product would be correctly classifiable?

iv. What is the applicable rate of GST on the supply of the product?

4. Applicant’s interpretation of law:

i. the advance ruling sought in the present application relates to classification of product manufactured and supplied by the Applicant, and accordingly, the instant application is covered under Section 97(2) (a) of the CGST Act and the corresponding provision of the TNGST Act.

ii. the product is classifiable under Chapter Heading 3921, and more specifically under tariff items 3921.90.22 and 3921.90.29, and accordingly, it is chargeable at the rate of 18% (COST and SGST each @9%) in terms of Entry No. 122 of schedule II of Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025 and 18% (IGST) in terms of Entry No. 122 of Schedule II of the Notification No. 09/2025- Integrated Tax (Rate) dated 17.09.2025, and may not be classified under CH 5903.

iii. Section VII of the Customs Tariff inter-alia covers Plastics and articles thereof while Section XI covers Textile and Textile Articles’. Since the product is a combination of both textile and plastic materials, both Sections assume relevance for the classification.

iv. Note 1 (h) to Section XI provides that this section does not cover woven, knitted or crocheted fabrics, felt or nonwovens, impregnated, coated, covered or laminated with plastics, or articles thereof, of Chapter 39.

v. Note 1 to Chapter 39 provides that throughout the Nomenclature any reference to “plastics” also includes vulcanised fibre, however, the expression does not apply to materials regarded as textile materials of Section XL Note 2(p) to Chapter 39 provides that this chapter does not cover goods of Section XI (textile and textile articles)

vi. a conjoint reading of Note 1(h) to Section XI and Note 2(p) to Chapter 39 reveals that mutual exclusivity exists between Chapter 39 and Section XI, effectively precluding concurrent classification under both.

vii. Chapter 59 under Section Xl of the Customs Tariff covers “impregnated, coated, covered or laminated textile fabrics; textile articles of a kind suitable for industrial use”, Note 1 of Chapter 59 provides that the expression “textile fabric” applies only to the woven fabrics of Chapter 50 to 55 and headings 58.03 and 58.06, the braids and ornamental trimmings in the piece of heading 5808 and the knitted or crocheted fabrics of headings 6002 to 6006. The scheme of the Chapter indicates that it provides classification for the coated textile fabrics or of textile articles of the kind that are suitable for industrial use.

viii. The product is a textile fabric which is entirely coated with plastic on both sides, where the coating is visible to the naked eye. Accordingly, the product satisfies the criteria elucidated in Chapter Note 2(a)(3) to Chapter 59, and is thereby specifically, excluded from Chapter 59 and merits classification under Chapter 39.

ix. The product utilizes the fabric base solely for structural reinforcement, while the dominant PVC coating provides the essential functional character. Further, as our product fulfils the “sandwiched” criteria and serves a reinforcing function, as explained in ‘Customs Classification of Textiles and Textile Articles under HSN —Explanatory Notes’ by Ajay Kumar Gupta, it shall be excluded from CH 5903.

x. Since the product is composed of a woven fabric coated with PVC, i.e. plastic and is not a felt, nonwoven or of cellular plastics, it does not fall within the inclusions or exclusions specified in Note 3 to Chapter 56.

xi. There are US Cross Rulings supporting the applicant’s argument on the classification of the product.

xii. since the product is in the form of rectangular sheets as well as uncut rolls, the product would be covered within the ambit of heading 3921, is classifiable under tariff entries 3921.90.22 or 3921.90.29 and is consequently taxable at the rate of 18% (COST and SGST each @9%) in terms of Entry No. 122 of Schedule II of the CGST Rate Notification and 18% (IGST) in terms of Entry No. 122 of Schedule II of the IGST Rate Notification.

5. The applicant is under the administrative control of State. The concerned authorities of the Centre and State were addressed to report if there are any pending proceedings against the applicant on the issues raised by the applicant in the ARA application and for comments on the issues raised. As remarks have not been received from the Centre and State authorities, it is assumed that there are no pending proceedings against the applicant on the issues raised by the applicant in the ARA application.

6. Personal Hearing

Ms. Derlene Joshna and Ms. Deepta appeared for the personal hearing as the authorized representative (ARs) of M/s. SRF Limited. The ARs reiterated the submissions made in their application for Advance Ruling and presented samples of the double-sided PVC coated fabric. The ARs also produced copies of judgements/ advance ruling order and US CROSS Ruling orders in support of their contention that the PVC coated fabric is liable to be classified under HSN 3921 and not under ISSN 5903 and sought ruling on the classification and applicable GST rate for the said product.

7. Discussions and Findings:

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

 7.2.  We find that the questions raised by the applicant, as mentioned in Para 3 above are liable for admission as it gets covered under Section 97 (2) (a) & (e) of CGST/TNGST Act, 2017 under “Classification of any goods or service or both”, and “Determination of the liability to pay tax on any goods or services or both”.

 7.3.  The applicant is engaged in the manufacture of Double-sided PVC Coated polyester (woven) Fabric, which finds application in Outdoor Awnings and Covers, Protective Machine/ Equipment Coverings, Tents and Seat Covers. The applicant has submitted images of the above product and brought samples of the same during the personal hearing. On looking at the product, we find it to be a flexible sheet having a smooth, uniform surface with/without lacquering and with no woven texture, weave pattern, or yam structure visible to the naked eye. The applicant states that the product is coated on both sides with PVC and has produced a test report certifying the same from. They also state that the approximate percentage composition of the individual components that go into the product is as follows:

 7.4. We note that Classification under GST is governed by the HSN as notified, applied in terms of the General Rules for the Interpretation (GRI) of the Customs Tariff, read with the Section Notes and Chapter Notes. Rule 1 of the GRI provides that classification is to be determined according to the terms of the headings, and any relative Section or Chapter Notes, and only where the headings and notes do not otherwise require, recourse gets made to the subsequent provisions. We now take up the HSNs proposed for classification by the applicant for the product and analyse the same.

7.4.1. HSN 5903

a. Chapter 59 covers ‘Impregnated, coated, covered or laminated textile fabrics; textile articles of a kind suitable for industrial use’ and falls under Section XI of Customs Tariff.

b. As per Section note 1(h) of Section XI of Customs Tariff, this section does not cover `at) woven, knitted or crocheted fabrics, felt or nonwoven, impregnated, coated, covered or laminated with plastics, or articles thereof of Chapter 39

c. As per Chapter note 2 of Chapter 59,

d. Heading 5903 applies to:

(a) textile fabrics, impregnated, coated, covered or laminated with plastics, whatever the weight per square metre and whatever the nature of the plastic material (compact or cellular), other than:

1. fabrics in which the impregnation, coating or covering cannot be seen with the naked eye (usually Chapters 50 to 55, 58 or 60); for the purpose of this provision, no account should be taken of any resulting change of colour;

2. products which cannot, without fracturing, be bent manually around a cylinder of a diameter of 7 mm, at a temperature between 15 C and 30 C (usually Chapter 39);

3. products in which the textile fabric is either completely embedded in plastics or entirely coated or covered on both sides with such material, provided that such coating or covering can be seen with the naked eye with no account being taken of any resulting change of colour (Chapter 39);

4. fabrics partially coated or partially covered with plastics and bearing designs resulting from these treatments (usually Chapters 50 to 55, 58 or 60);

5. plates, sheets or strip of cellular plastics, combined with textile fabric, where the textile fabric is present merely for reinforcing pwposes (Chapter 39); or

6. textile products of heading 5811;

(b) fabrics made from yarn, strip or the like, impregnated, coated, covered or sheathed with plastics, of heading 5604.

d. Section notes 1(h) of Section XI of Customs Tariff excludes from Section XI any woven, knitted or crocheted fabrics, felt or nonwovens, impregnated, coated, covered or laminated with plastics, or articles thereof, of Chapter 39. We therefore observe that the above Section notes exclude the product, being a woven fabric coated with plastics, from Section XI and directs the classification towards Chapter 39 (Plastics).

e. Further, as per the exclusion (3) to Chapter note 2(a) of Chapter 59, Heading 5903 applies to textile fabrics, impregnated, coated, covered or laminated with plastics other than ‘products in which the textile fabric is either completely embedded in plastics or entirely coated or covered on both sides with such material, provided that such coating or covering can be seen with the naked eye’. The product manufactured by the applicant is a polyester woven fabric covered completely with PVC coating. The polyester textile substrate is embedded/covered completely within the PVC layers, and the woven texture, weave pattern, or yarn structure of the fabric is completely hidden under the coating. Further, the coating is visible with the naked eye. We therefore find that the product falls within the exclusion (3) to Chapter note 2(a) of Chapter 59. This asserts that the product does not fall under the HSN 5903.

f. In view of the specific exclusion from Chapter 59 and from HSN 5903, the product is directed towards classification under Chapter 39 as per the above Section and Chapter Notes. We also note that in the product, the plastic-related content (PVC + chemicals) is 68% and the textile content is only 32%, thereby strengthening the classification under Chapter 39.

7.4.2. HSN 3921

a. Chapter 39 covers Plastics and articles thereof’ and falls under Section VII of Customs Tariff. We note that the headings 3901 to 3914 cover plastics in primary form. The product in question being a ‘sheet’ obviously does not fall under the headings 3901 to 3914. We detail below the other headings falling under the Chapter 39 and proceed to analyse the classification of the product thereafter:

b. We find that the double-sided PVC coated woven fabric does not fall under any of the specifically enumerated entries from HSN 3915 to 3920 and 3922 to 3925. We proceed to check whether the product could be classified under HSN 3921.

c. The HSN 3921 covers “Other plates, sheets, film, foil and strip, ofplastics”. As per Chapter note 10 of Chapter 39,

10. In headings 3920 and 3921, the expression “plates, sheets, film, foil and strip” applies only to plates, sheets, film, foil and strip (other than those of Chapter 54) and to blocks of regular geometric shape, whether or not printed or otherwise surface-worked, uncut or cut into rectangles (including squares) but not further worked (even if when so cut they become articles ready for use)

d. The double-sided PVC coated plastic sheet manufactured by the applicant being in the form of rectangular sheets or uncut rolls, are therefore rightly classifiable under heading 3921 as per Chapter note 10 of Chapter 39.

e. We further proceed to arrive at the eight-digit subclassification of the product. The broad subclassification of heading 3921 is as below:

g. We note that ‘Cellular’ plastics are polymers containing numerous small gas-filled cells or voids throughout their volume, giving them a lightweight, foam-like structure, and are widely used in packaging, insulation, cushioning, automotive, construction etc. Since the PVC coating in the product gives a smooth finish having no voids, we find that the same is not a cellular plastic. The applicant has also confirmed the same in their written submission. We therefore tend to classify the product under ‘other’. We note that HSN 39219021 to 39219029 cover `other plates, sheets, film, foil and strip of PVC’. We therefore detail the said HSNs below:

g. The double-sided PVC coated plastic sheet is flexible and may or may not be lacquered. We therefore conclude that the HSN of the product, when lacquered and when not lacquered is 39219022 and 39219029 respectively.

7.5. Now we take up the issue of the applicable rate of GST for the above product. Notification No.1/ 2017-Central Tax (Rate) dated 28.06.2017 prescribes the GST rate schedules for intra-State supply of goods, and it stands amended vide Notification No.9/2025-Central Tax (Rate) dated 17th September 2025.

7.6. As per s.no. 122 of Schedule II of the amended Notification, the applicable CGST rate for the products falling under HSN 3921, and described below is 9%:

“Other plates, sheets, film, foil and strip, of plastics”

7.7. It therefore follows that the total GST rate for Double-sided PVC Coated polyester (woven) Fabric falling under HSN 3921 is 18%.

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

Ruling

i. Whether the product is classifiable under Chapter Heading 3921? Answer: Yes

ii. Whether the product is classifiable under Chapter Heading 5903? Answer: No

iii. In case answer to (i) and (ii) are in negative, what is the HSN under which the product would be correctly classifiable?

Answer: Not applicable

iv. What is the applicable rate of GST on the supply of double-sided PVC Coated Fabric?

Answer: CGST – 9%, SGST – 9%, Total – 18%