In re Apple Operations International Limited (CAAR Delhi)
In the case of In re Apple Operations International Limited (Order No. 16 of 2025) issued by the Customs Authority of Advance Ruling (CAAR) Delhi, the classification of the Pearl Assembly Module Subassembly in the context of the Indian Customs Tariff was analyzed. The Pearl Assembly Module Subassembly, which houses components like the front-facing camera and Face ID module, serves multiple functions, including capturing images, video recording, and enabling facial recognition features. Despite the components working together, each subassembly serves separate functions, one for image capture and the other for Face ID recognition, primarily for mobile phones.
The ruling focused on determining the correct classification of this subassembly under the Customs Tariff, applying the General Rules of Interpretation (GIR) and the Harmonized System Nomenclature (HSN) Explanatory Notes. The applicant, Apple Operations International, sought to classify the Pearl Assembly Module Subassembly under CTH 8525, a heading for digital cameras. However, the CAAR concluded that since the subassembly does not have independent storage or other features like an optical viewfinder or display that are characteristic of digital cameras, it did not meet the criteria for CTH 8525. The product was found to be a “part” of a mobile phone, qualifying under CTH 8517, which covers “telephone sets, including those for cellular networks.”
