In re Ibiden Singapore Pte Limited (CAAR Mumbai)
The Customs Authority for Advance Rulings (CAAR) in Mumbai recently delivered a decision on the classification of raw silicon carbide bricks used in diesel particulate filters (DPF) in the case of Ibiden Singapore Pte Limited. This decision is crucial for determining the correct customs duty applicable to these goods upon their import into India.
Product Background and Classification Challenge
The product in question is a “Silicon Carbide Brick” utilized in DPF applications. Silicon carbide bricks are refractory materials, meaning they are resistant to high temperatures, which makes them suitable for such applications. The classification issue arose because the bricks are composed mainly of silicon carbide and are crucial components in DPF systems.
Examination of Relevant Chapters and Notes
The CAAR examined the potential classifications under various chapters of the Customs Tariff. Specifically, they considered Chapter 85, which covers electrical machinery and equipment, but found no heading that explicitly includes silicon carbide bricks. Similarly, Chapter 84, which encompasses machinery and mechanical appliances, was also deemed inappropriate as it explicitly excludes ceramic materials and ceramic parts of machinery, directing such items to Chapter 69.
Detailed Analysis Under Chapter 69
Chapter 69 deals with ceramic products. The CAAR delved into Heading 6902, which covers refractory bricks, blocks, tiles, and similar constructional goods made from ceramics, excluding those made from siliceous fossil meals or similar siliceous earths. Under this heading, subheading 6902 20 includes refractory goods containing more than 50% by weight of alumina (Al2O3), silica (SiO2), or a combination of these compounds. Specifically, CTI 6902 2040 covers silicon carbide bricks and shapes.
