In re Apple Operations International (Ltd.) (CAAR Delhi)
The Customs Authority for Advance Ruling (CAAR), Delhi, analyzed the classification of the Back Glass Subassembly, a crucial component of mobile phones. This assembly, comprising a back glass panel, flex circuits, magnets, and additional elements like charging coils and microphones, performs multiple functions such as structural support, wireless charging, flashlight utility, and sound reception. Integrated with the mobile phone’s main logic board, this component enhances both functionality and protection. However, it does not have an independent principal function, making its classification under Customs Tariff a complex matter.
Applying the General Rules of Interpretation (GIR), the authority determined the Back Glass Subassembly’s classification under Chapter 8517 as “Parts” of mobile phones. This decision was guided by statutory rules, HSN Explanatory Notes, and judicial precedents, emphasizing its sole and specific use with mobile phones. Notably, Section Note 2 to Section XVI clarified that parts suitable exclusively for machines under a particular heading should be classified accordingly. Thus, the Back Glass Subassembly was conclusively categorized as a part under CTH 8517, reflecting its integral role in mobile phone manufacturing.
EXTRACT OF THE ORDER OF CUSTOMS AUTHORITY OF ADVANCE RULING, DELHI
Analysis and Conclusion
5. The Back Glass Subassembly is a structural and functional component of a mobile phone consisting of rear glass panel along with associated elements which enables wireless charging, microphone and flashlight functions. The Back Glass Subassembly provides both protection and functionality to the mobile phones. The housing of the Back Glass Subassembly comprises of the following components —a. Back Glass; b. Back Glass Flex (consisting of charging coil, flashlight, and microphone); c. Magnets. The Back Glass, Back Glass Flex, and Magnets are bonded together to form the Back Glass Subassembly through an advanced adhesive application process. After importation, Black Glass subassembly is integrated into the MLB of the mobile phone through the FPCBA. Here it is also pertinent to mention that the Back Glass subassembly may comprise of additional parts which may be added to provide structural integrity to the subassembly and will assist in the integration of the subassembly in the mobile phone or maybe used as a placeholder for other parts of mobile phone. Thus, these additional component or parts will not alter the principal function of the subassembly.
