In re Tata Ficosa Automotive Systems Private Limited (CAAR Mumbai)
The Customs Authority for Advance Rulings (CAAR), Mumbai, delivered a ruling in the matter of Tata Ficosa Automotive Systems Private Limited concerning the Customs Tariff classification of three imported components intended for the assembly of Low Voltage Differential Signaling (LVDS) cameras. These cameras are integral to the company’s vision-based Advanced Driver Assistance System (ADAS) products used in automobiles.
The applicant, Tata Ficosa, a manufacturer of automotive systems, sought an advance ruling on whether the imported items—the LVDS (HD) Camera Lens, the Back Housing (Aluminium Housing + Plastic Fakra Connector), and the Front Housing of the LVDS camera—should be classified under Customs Tariff Item (CTI) 85299090 as “parts” of the LVDS camera. The company intended to import these components in separate shipments from China, while a crucial component, the Printed Circuit Board Assembly (PCBA), would be sourced domestically to complete the camera assembly in India.
Arguments and Statutory Framework
Applicant’s and Jurisdictional Authority’s Stance
The applicant contended that a fully functional LVDS camera is classifiable under Customs Tariff Heading (CTH) 8525, which covers television cameras, digital cameras, and video camera recorders. Following this, the components, being tailor-made and solely or principally suitable for use with the LVDS camera, should be classified as parts under CTH 8529, specifically under the sub-heading 85299090 (“Other”). The applicant relied on General Rule of Interpretation (GRI) 1, Note 2 to Section XVI of the Customs Tariff Act, and the World Customs Organization (WCO) Explanatory Notes to CTH 8525, which direct that parts of apparatus under CTH 8525 are classified in CTH 8529. The jurisdictional authorities concurred with this analysis.
