Architectural Decorative Stainless Steel Wall Panels falls Under CTH 7219 90 90: CAAR

In re Manuel Steel Decor (CAAR Mumbai)

An application for advance ruling was filed before the Customs Authority for Advance Rulings, Mumbai, by an importer proposing to commence import and sale of “Architectural Decorative Designer Wall Panel Articles of Stainless Steel” of different shapes, sizes, and finishes, with or without drilled holes in the corners. The application was received on 03.10.2025 under Section 28-I(1) of the Customs Act, 1962. The applicant sought clarification on the correct tariff classification of the proposed imports, suggesting classification either under Customs Tariff Heading 7308 90 90 (structures and parts of structures) or 7326 90 60 (other articles of stainless steel).

The applicant explained that the goods are fully manufactured, dimensioned, surface-finished stainless steel panels, including finishes such as mirror polish, hairline, satin, embossing, etching, sand blasting, PVD coating, and anti-fingerprint coatings, with protective PVC films. These panels are intended for permanent architectural, structural, and decorative applications such as façade cladding, wall panelling, roofing systems, ceilings, partitions, pillars, elevator interiors, and transportation infrastructure. According to the applicant, depending on use and presence of mounting holes, the panels could be considered either parts of structures or independent finished stainless steel articles.

The applicant relied on the World Customs Organization Harmonized System Explanatory Notes, arguing that the goods were “further worked” finished products and not raw materials. It was also submitted that identical goods had been cleared at certain ports under headings 7308 or 7326. No comments were received from the jurisdictional customs commissionerate despite multiple references. During the personal hearing, the applicant reiterated its submissions and emphasized that the panels form an integral and immovable part of the built environment.

The Authority examined the application, written submissions, manufacturing process, photographs, and oral arguments, along with the relevant provisions of the Customs Act, the Customs Tariff Act, the General Rules for Interpretation (GIR), and the Harmonised System of Nomenclature (HSN) Explanatory Notes. The Authority noted that it was not bound by the tariff headings proposed by the applicant and was required to determine the correct classification independently.

On examination, the Authority found that the goods are manufactured from flat-rolled stainless steel sheets, which are cold-rolled and then cut to size and subjected to various surface finishing processes. The imported goods consist of flat stainless steel panels of uniform thickness ranging from about 0.4 mm to 3 mm, in rectangular, square, circular, or triangular shapes. Despite the extensive surface treatments and decorative finishes, the Authority held that the essential character of the goods remained that of flat-rolled stainless steel products.

Reference was made to Chapter 72 of the Customs Tariff, particularly Heading 7219, which covers flat-rolled products of stainless steel of a width of 600 mm or more. Chapter Note 1(k) to Chapter 72 clarifies that flat-rolled products may be polished, perforated, corrugated, or otherwise finished, provided they do not assume the character of articles or products of other headings. The HSN Explanatory Notes further clarify that surface treatments and mechanical working do not alter classification as long as the products retain the character of flat-rolled products.

The Authority observed that processes such as polishing, embossing, etching, PVD coating, anti-fingerprint treatment, and PVC lamination merely enhance appearance, corrosion resistance, and durability. These processes do not create a new product with a distinct name, character, or use, nor do they alter the fundamental identity of the goods as flat-rolled stainless steel products. Judicial precedents were noted to support the principle that surface treatment or lamination does not change the essential character of the base metal product.

The applicability of Heading 7308 was examined and rejected on the ground that the goods are not identifiable as structures or parts of structures such as beams, columns, frames, or trusses performing a structural function. Mere use of stainless steel panels for cladding or decorative purposes does not make them “parts of structures” under Heading 7308. Similarly, Heading 7326, being a residuary heading for “other articles of iron or steel,” was held inapplicable because the goods are specifically covered under Heading 7219.

Applying Rule 1 of the General Rules for Interpretation, the Authority concluded that classification must be determined according to the terms of the headings and relevant chapter notes. Since the goods are flat-rolled stainless steel products, they fall squarely under Heading 7219. Rule 3 was found inapplicable, and applying Rule 6 at the sub-heading level, the appropriate classification was determined as 7219 90 90.

FULL TEXT OF THE ORDER OF CUSTOMS AUTHORITY OF ADVANCE RULING, MUMBAI

M/s Manuel Steel Decor (IF,C No. EKYPS6567Q) (hereinafter referred to as ‘the applicant’) filed an application (CAAR-1) for advance ruling before the Customs Authority for Advance Rulings, Mumbai (CAAR in short). The said application was received in the secretariat of the CAAR, Mumbai on 03.10.2025 along with its enclosures in terms of Section 2811 (1) of the Customs Act, 1962 (hereinafter referred to as the ‘Act’ also). The applicant is seeking advance ruling on Eligibility of getting classified the “Architectural Decorative Designer Wall Panel Article of Stainless Steel or different shapes, sizes and finishes with or without drilled hole in corner” under Customs Tariff HS Code 73089090 or 73269060 for the import of the said goods in different consignments from a few foreign countries such as China. Japan, Taiwan, Hong Kong, Indonesia, Malaysia etc. – reg.

2. Submission by Applicant

The applicant has informed that M/s Manuel Steel Decor (11′,C: FKYPS6567Q) intends to commence a business of import and sale of ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes with or without drilled hole in corner’ in India. The item and its utility arc given below:

2.1 Item & its utility:

2.1.1 Background – In the present matter, the applicant, M/s Manuel Steel Decor intends to import the ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes with or without drilled hole in corner’ in diRrent consignments from a few Ibreign countries such as. China. Japan. Taiwan. Hong Kong. Indonesia. Malaysia etc.

2.1.2 Features: The said goods arc —

i) “Architectural Decorative Designer Wall Panel Articles of Stainless Steel in various shapes, sizes, and surface finishes with or without drilled holes in the corners, arc fully manufactured and dimensioned products. These panels may he surface-finished, multi­dimensional. multi-coloured, or PV D (Physical Vapour Deposition) coated,, and are further protected with a PVC film to prevent damage. They are specifically designed, prepared, and intended for direct, permanent use in architectural, structural, and decorative applications. Being fully finished and coated articles, they are not raw materials but completed article meant for installation.”

ii ) These specially designed Architectural Decorative Designer Wall Panel Articles arc used for facade cladding system by installing as external wall cladding on high-rise buildings, commercial towers, airports, hotels, shopping malls, and institutional buildings. These panels are mechanically fixed or structurally bonded onto facade sub-frames or vertical grid systems using concealed brackets, rivets, or structural adhesives. Once installed, they protect the building envelope. provide weather resistance, and create a modern architectural appearance. These remain permanently in position and arc designed to withstand wind impact, and environmental loads, thermal expansion, and other structural stresses.

iii) These specially designed Architectural Decorative Designer Wall Panel Articles are used as wall panelling and internal cladding also. Once fixed, they form a permanent. immovable part of the building’s envelope or interior structure.

iv) These specially designed Architectural Decorative Designer Wall Panel Articles are dimensioned or slotted as needed for mechanical fixing during manufacturing and Installation which involves stainless steel fasteners, concealed anchors, sub-frames, brackets, or high-strength structural adhesives.

v) These specially designed Architectural Decorative Designer Wall Panel Articles arc deployed as permanent wall panels. roof panels, ceiling covers, and feature screens in metro stations, railway concourses, airport terminals, bus depots, and passenger waiting halls. These Panels provide durability, vandal resistance, easy cleaning, and fire safety.

vi) These specially designed Architectural Decorative Designer Wall Panel Articles arc used in multiple architectural, structural, and decorative infrastructure applications where they form an integral and immovable part of the built environment. Owing to their lustrous surface finishes they ensure durability, longevity and enhanced decorative appeal, thereby fulfilling the requirements of l leading 73089090 or 73269060 under the Customs Thri II Act. 1975.

2.1.3 Core functions/utility of the said goods: These ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel of’ different shapes, sizes and finishes’ are intended for various architectural/structural and decorative applications. Some core finctions/utility of’ the said “Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes” are listed below:

a) Facade Cladding Systems: Installed as external wall cladding on high-rise buildings, Commercial towers, airports, hotels, shopping malls, and institutional buildings. These ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes’ are mechanically fixed or structurally bonded onto facade sub-fames or vertical grid systems using concealed brackets, rivets, or structural adhesives. Once installed. they protect the building envelope, provide weather resistance, and create a modern architectural appearance. Remain permanently in position and arc designed to withstand wind loads. thermal expansion, and other structural stresses.

b) Wall Panelling and Internal Cladding: Applied as interior wall panels in lobbies, ebrridors, atriums, ‘hospitals, luxury retail spaces, and corporate offices, metro stations, airports, and railway terminals etc. These ‘Architectural Decorative Designer Wall Panel Article of Staitil6;s; Sieel of different shapes, sizes and finishes’ are installed using clip systems or structural fixings directly onto wall studs or metal sub-frames.

c) Roofing Systems: Fabricated as part of modern architectural roofing frameworks or visible roof panels which are dimensioned and finished to interlock or overlap, providing a seamless roof covering that is durable and corrosion-resistant. These ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes’ are typically fixed using stainless steel screws, concealed clips, or welding for weatherproof’ installation.

d) Partitions and Structural Screens: These ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes’ are used as semi-structural partition walls within commercial, industrial, or institutional buildings and these provide both functional separation and an architectural feature wall. These arc fixed onto metal studs or partition frameworks by mechanical fasteners and often combined with acoustic or insulation layers for noise control.

e) Ceiling Systems: Installed as decorative or functional ceilinit panels in commercial lobbies. transport hubs. showrooms. or public halls, these arc suspended using concealed grid systems, clips, or brackets and thereby contribute to aesthetics, acoustic control, and ease of maintenance. They remain permanently installed until ceiling renovation or demolition.

f) Pillar and Column Covers: Clad structural columns or beams or pillars for both protection and aesthetics and provide seamless finishes around load-bearing structural elements. These ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel. of different shapes, sizes and finishes’ arc fixed by mechanical framing system that wrap around the pillar’s core.

g) Structural and Decorative Flooring: Installed in selected commercial or industrial environments (e.g., hospitals, food processing, and luxury interiors) where stainless steel flooring panels provide structural strength and .design appeal. These ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel of diftrent shapes. sizes and finishes are permanently bonded or mechanically fastened to the sub floor.

h) Architectural Elements in Transportation Infrastructure: Deployed as permanent wall panels. roof panels, ceiling covers. and feature screens in metro stations, railway concourses, airport terminals, bus depots, and passenger waiting halls. These ‘Architectural Decorative Designer Wall.Panel Article of Stainless Steel oldifferent shapes, sizes and finishes provide durability, vandal resistance, easy cleaning. and fire safety and these arc fixed mechanically for decades-long service life as a structural part of the built infrastructure

i) Elevator infrastructure: These ‘Architectural Decorative- Designer Wail Panel Article of Stainless Steel of different shapes, sizes and finishes, when installed in elevator shafts and cabins ensures the vertical guidance of the elevator car and counterweight, thereby simplifying integration of elevators in new constructions without heavy structural modifications, ensure a smooth. vibration-free ride. ensure the structural safety and stability and thereby enhance experiences of users. especially in premium commercial and residential buildings. It ensures the elevator car which remains vertically aligned. allowing for exact stopping and door levelling mechanisms to function correctly and provide durability, long service life, overall stability and safety.

2.1.4. Multi-dimensioned and fully finished Architectural Decorative Designer Wall Panel Article of Stainless Steel:

These “Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes with or without drilled holes in corner’ arc specifically designed and fully dimensioned multi-dimensional finished articles. They arc surface-treated and prepared for permanent use in a variety of architectural, structural, and decorative applications (photographs enclosed).

2.1.5 To get the clarity regarding appropriate classification of the item ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes with or without drilled holes in corners’, the applicant seeks to obtain an advance ruling on the same.

3. Applicants’ interpretation of Law/Facts: -Applicant has submitted that the eligibility of getting classified the “Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes with or without drilled hole in corner” under Customs Tariff HS Code 73089090 or 73269060 for import of the said goods in di fferent consignments from a few foreign countries such as China. Japan. Taiwan, I long Kong. Indonesia, Malaysia etc.. are hereunder:

Subject goods “Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes with or without drilled hole in corner” are parts of various architectural, structural and decorative applications intended to he used fbr facade cladding systems, wall panelling and internal cladding, structural and decorative flooring. Roofing Systems, Partitions and Structural Screens, Ceiling Systems, Elevator Infrastructure, Pillars and Column Covers and architectural elements in transportation infrastructure etc., hence these goods are rightly classifiable under CTI 1 73089090 or 73269060:

3.(A) World Customs Organization Harmonized Commodity Description and Coding System Explanatory Notes: The applicant has also submitted that –

As per the General Note ‘(IV) Production of finished products’ of the World Customs Organization I iarmonized Commodity Description and Coding System Explanatory Notes the finished products may be subjected to further finishing treatments or converted into other articles by a series-of operations _like Mechanical Working i.e. perforation and punching etc. and Surface Treatments or other operations including cladding, coating or polishing etc., to improve the properties or appearance of the metal, protect it against rusting and corrosion etc. The relevant portion of the WCO Explanatory notes is reproduced below:

“(C) Subsequent manufacture and finishing

The finished products may be subjected tojiirther finishing treatments or converted into other articles by a series of operations smelt as:

(1) Mechanical working, i.e., turning, milling, grinding, perforation or punching, Pitting, si=ing, peeling. etc.: however, it should be noted that rough turning merely to eliminate the oxidation scale and crust and rough trimming are not regarded as finishing operations leading to a change in classification.

(2) Surface treatments or other operations, including cladding, to improve the properties or appearance of the metal, protect it against rusting and corrosion. etc.”

The subject goods are multi-dimensioned, shaped, surface finished/PM (Physical Vapour Deposition) coated/coloured, SOIllelinleS embossed/etched designed and with or without hole/perfOration, finished ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel”, which are widely used for architecturalAtructuralidecorcitive applications and therefore, these goods are rightly classifiable under CM 73089090 or 73269060.

Furthermore, as per the principle 3(c) of the General Rules fir the Interpretation of Import Tariff when the goods arc prima fhcic, classifiable under two or more headings, the uoods should he classified under the heading which occurs last in numerical order among those which equally merit consideration. Therefore, the subject goods may he classified under CFI 173269060.

3.(B) “Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes. sizes and finishes with or without drilled hole” are specifically designed and manufactured to provide lustrous surface finishes, ensure long-lasting durability. and serve exclusively for architectural, structural and decorative purposes:

The final surface finishes imparted to the ‘Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and _.finishes with or without drilled hole” may include, but shall not be limited to, the following aesthetic and functions. All such finishing processes are carried out exclusively on mill-finish. semi-finished flat rolled stainless steel materials, which have been cold rolled, annealed. pickled, and skin-passed to produce a smooth. uniform base surface suitable for further processing. A few types of’ finishes are enumerated. below:

i) 8K Mirror Finish:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: Achieved through• progressive mechanical polishing using multiple stages of increasingl finer abrasive belts and polishing compounds—Typically starts with coarse grit (e.g.. 150 -320 grit) for levelling, followed by medium grit (100—600 grit), and finishing with ultra-fine polishing wheels and buffing compounds (using felt wheels and diamond rouge). Final polishing reaches a reflectivity rating of approximately 8000 grit equivalence —– hence the term `8K’.
  • Machinery Used: Automatic or semi-automatic polishing lines, rotary buffers, felt wheels with buffing compounds, clean-room polishing setups for premium output.

Result: Produces a high-gloss, mirror-like finish suitable for decorative panels. premium interiors, or architectural features where maximum reflectivity is desired.

ii) 10K Mirror Finish:

• • 13ase Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: Similar multi-stage polishing as 8K but with additional ultra-line finishing. Uses micro-grit compounds (sub-micron size) and extra buffing passes under clean-room conditions to remove any micro-scratches or swirl marks.
  • Machinery Used: High-speed, precision buffing units with micro-fiber polishing pads: controlled environment for final pass to avoid contamination.

Result: Yields an ultra-premium, highly reflective finish surpassing the standard 8K. producing a near-flawless mirror surface used for luxury facades, lift cabins, or designer interiors.

• • Technical Process: Produced by unidirectional brushing using continuous abrasive belts of typically 120 -180 grit, creating fine, straight, parallel lines along the length of the sheet.
  • Machinery Used: Ilairline polishing machines equipped with continuous belt grinders and dust extraction.

Result: Provides a refined linear texture that diffuses reflections, conceals minor scratches. and is popular for cladding, appliance panels. and decorative wall features.

iv) Cross Hairline Finish:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: Involves first producing a standard hairline in one direction, then re­processing the sheet through a cross-brushing unit at a controlled angle (usually 45 or 90 degrees) to create intersecting lines.
  • Machinery Used: Double-axis brushing machine or sequential brushing in two passes. Result: Creates an intersecting crosshatch pattern that offers unique visual depth and is used for premium architectural panels or signature design features.

v) Satin Finish:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: Generated by brushing with non-woven abrasive belts of approximately 180-320 grit to create a soli:, non-directional, low-sheen surface.
  • Machinery Used: Satin finishing machines with wide abrasive belts and tension rollers for uniformity.

Result: Yields a muted. smooth matte effect that reduces glare and is resistant to fingerprints, making it suitable for kitchen appliances, wall panels, and interiors.

vi) Scotch Bright Finish:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: Produced by finishing with non-woven Scotch-BriteTm pads or wheels (fine to ultra-fine grade) to achieve a uniform, dull-polished look with soft grain.
  • Machinery Used: Manual or automatic Scotch-Brite machines with rotating pads. Result: Easy to maintain, hides fingerprints, and provides a unifbrm decorative sheen used in elevators, railings, and trims.

vii) Sand Blast Finish:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: The surface is blasted with line abrasive media (e.g., silica sand, aluminium oxide) using compressed air or suction blasting. Typical blasting pressure ranges from 3 to 6 bar with controlled nozzle distance for uniform texture.
  • Machinery Used: Closed-cabinet or open-cabinet sandblasting equipment with dust collection.

Result: Produces a matte, grainy texture that diffuses light reflection and provides anti-slip properties; used for exterior cladding or artistic panels.

viii) Water Repellent Finish:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical ProceSs: Application of hydrophobic nano-coating or fluoropolymer-based spray that chemically bonds to the stainless-steel surface, creating a contact angle that causes water to bead and roll off.
  • Machinery Used: Spray booth or roll-coating equipment with UV or thermal curing where required.

Result: Prevents water spots and facilitates easy cleaning, ideal for facades, signage. and exterior architectural panels.

ix) Linen Finish:

• • Base Material: Mill finish. semi-finished flat rolled stainless steel material.
  • Technical Process: Created by passing the panel through an embossing mill with engraved rollers that imprint a woven linen-like texture.
  • Machinery Used: Ileavy-duty embossing mill with matched pattern rollers.

Result: Adds a fabric-inspired tactile pattern for decorative applications in lift interiors, wall panels, or bespoke architectural features.

x) Brush Finish:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: Similar to hairline but with a coarser grit (80-120) and often less directional brushing, providing a visibly brushed appearance with more pronounced texture.
  • Machinery Used: Brushing lines with multiple brushing heads or wide belt grinders. Result: Conceals handling marks. widely used for architectural and appliance applications.

xi) Vibration Finish:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: The panel is secured on a vibration table with abrasive media that moves in random circular motions. producing a non-directional swirl pattern.
  • Machinery Used: Vibration finishing machines with adjustable oscillation frequency and abrasive media flow.
  • Result: Creates an organic, non-repetitive texture that hides scratches and fingerprints; commonly used for decorative panels and interior designs.

xii) Anti-I in:2,er Finish:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: Application of a thin nano-ceramic or polymer-based transparent coating that forms a protective, smudge-resistant layer.
  • IVIachinery Used: Roll coating lines or automated spray booths with controlled curing. Result: Reduces fingerprint marks and smudges in high-contact areas like lift doors, wall cladding. or household appliances.

xiii) Etching Designs:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: The desired pattern is masked with a resist material; the exposed areas arc chemically etched using ferric chloride or other acid solutions to create a recessed design.
  • Machinery Used: Automated etching lines with precise resist application and acid circulation tanks.

Result: Produces detailed, permanent patterns used for branding, decorative facades, and custom architectural panels.

xiv) Embossed Designs:

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: The panel is fed through matched rollers or a press die which imprints raised or recessed patterns on the metal.
  • Machinery Used: I Leavy-duty embossing presses or pattern roller mills.

Result: Adds 31) texture for both visual and functional effect (e.g., slip resistance, visual branding); common in decorative ceilings and wall panels.

xv) PVD Coating (Physical Vapour Deposition):

• • Base Material: Mill finish, semi-finished flat rolled stainless steel material.
  • Technical Process: The panel is cleaned and placed in a vacuum chamber where metal vapours (e.g., titanium nitride) arc ionized and bonded to the stainless steel at high temperatures, forming a hard, coloured layer.
  • Machinery Used: I ligh-vacuum PVI) chambers with magnetron sputtering or arc evaporation.

Result: Provides durable, decorative metallic colours like Gold, Rose Gold, Black, Champagne, Grey, Silver, Blue, Green, Rustic Brown etc.; adds scratch resistance and a luxurious aesthetic for facades, interior decor, and premium cladding.

3.(C) Manufacturing process and surface finishes and final character of Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes with or without drilled holes in corners:

These Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes with or without drilled hole are not raw materials but fully finished articles. These arc manufactured by subjecting high-quality stainless-steel flat rolled material (initially in conventional mill finish condition) to systematic shaping, dimensional cutting, surface finishing, and protective treatments, which collectively transform them into articles suitable for direct end-use applications such as cladding, facades, roofing, partitions, interiors, and other architectural or structural installations. The detailed manufacturing process from Selection of Raw Materials to production of Architectural Decorative Designer Wall Panel Article of ‘Stainless Steel of different shapes, sizes and finishes with or without drilled hole’ are enumerated below for better understanding to classify the goods under CTII 73089090 or 73269060:

i) Raw Material Selection:

The process begins with selection of flat rolled stainless steel material in mill finish condition. Mill finish is the standard semi-finished state obtained through cold mlling. annealing, pickling, and skin passing, yielding a smooth, uniform base surface appropriate for further industrial processing.

ii) Cutting, Shaping, and Dimensioning (“Further Worked” condition):

a) Before any finishing process is undertaken, the material is cut to size in accordance with specific dimensional requirements.

b) Techniques employed include precision shearing, laser cutting, plasma cutting, and waterjet cutting, ensuring accuracy and suitability for architectural, structural and decorative applications.

c) The material is thus converted from undifferentiated flat rolled stainless steel into dimensionally defined panels in standard rectangular, square, triangular, or circular forms.

iii) Surface Processing and Finishing (“Further Worked” condition):

a) After cutting. the panels undergo a range or advanced surface finishing operations to impart distinct aesthetic and functional characteristics.

b) These finishes not only enhance appearance but also modify perfbrmancc attributes such as reflectivity, scratch resistance, texture, and anti-fingerprint properties.

c) Once processed. the panels are no longer semi-finished products but finished stainless-steel articles, directly usable in architectural, decorative. or structural applications.

iv) Detailed Technical DesCription of Surface Finishes:

All finishes are carried out exclusively on cut-to-size panels prepared from mill finish flat rolled stainless steel materials (i.e., “further worked” condition transforming base material into finished stainless-steel articles. The detailed types of finishes have already enumerated above.

v) Protective Treatment (After “Further Worked” conditions are satisfied):

After finishing, panels are laminated with protective PVC films (3C. 5C, 7C microns) to prevent scratches, abrasions, or environmental damage during transport and installation. The thickness of PVC (Polyvinyl Chloride) materials is often measured in microns or gauge.

– 3C PVC: approximately 150-230 microns (or 6-9 mils)

– 5C PVC: approximately 250-380 microns (or 10-15 mils)

– 7C PVC: approximately 380-500 microns (or 15-20 mils)

vi) Dimensions and Range (“Further Worked” conditions):

(a) Rectangular Panels (in inches)

12×18, 12×24, 18×32, 18×36, 24×32, 24×36, 24×49, 24×60, 24×72. 24×98, 32×36, 32×49, 32×60, 32×72, 32×98, 36×49, 36×60, 36×72, 36×98, 49×60, 49×72, 49×90, 49×98, 49×120

(b) Square Panels (in inches)

10×10, 12×12, 14×14, 18×18, 24×24, 32×32, 36×36, 49×49

(c) Triangular Panels _.(in inches)

6x6x6. 8x8x8. 10x10x10, 12x12x12, 14x14x14, 18x18x18, 24x24x24

(d) Circular Panels (in inchel;)

6, 7, 8, 9, 10, 11, 12, 13, 16, 18, 20, 21, 22,24

Permissible Thickness Range: 0.4 mm to 3 mm

vii) Quality Control:

Strict inspections arc conducted at every stage, covering dimensional accuracy, surface integrity, mechanical properties, and chemical composition verification. Only panels meeting defined standards arc released as finished stainless steel architectural/decorative/ structural articles.

viii) Additional “Further Worked” conditions:

a) Structural Application Panels (with Mounting I loles) as “Part of Structures”: Once the flat rolled stainless-steel material arc cut to dimension and surface finished as per the methods described above, certain panels intended for structural applications (for example. cladding elements forming part of a facade support system. roofing, or structural assemblies etc.) may require further working by creating mounting holes.

• • • • These holes are precisely drilled at the corners or along the edges of the panels to facilitate mechanical fastening with screws, bolts, rivets, or clamps.
      • Such treatment ensures that the panels are integrated into steel frameworks, load-hearing assemblies, or modular structural systems.

Therefore, when used in this form, the panels acquire the character of “parts of structures”, appropriately classifiable under I IS Code 73089090.

b) Architectural / Decorative Application Panels (without Mounting I Toles): -In contrast, panels used for architectural and decorative purposes (such as wall cladding. elevator interiors, ceilings. furniture elements, partitions. or decorative facades) do not necessarily’ require mounting holes, as they are often fixed using alternative methods, such as:

• • • • Adhesive Bonding Using high-strength industrial adhesives, epoxy resins. or construction-grade double-sided tapes.
      • I look-On / Clip-On Systems — Panels are slotted into concealed mounting clips or rails. giving a seamless finish.
      • Channel or Frame Inserts Panels are set into aluminium/steel channels, providing structural support without drilling.
      • Magnetic or Velcro Fixing Systems • Used for lightweight decorative panels requiring removability.

In such applications, the panels are independent finished decorative articles of stainless steel, which are appropriately covered under IIS Code 73269060 (Other articles of stainless steel). These panels, by virtue of cutting, finishing, optional Physical Vapor Deposition (PVD) coating. optional mounting provisions. and dimensional specification. arc complete finished products and these arc used as structural parts or decorative articles. Iherefore, these goods arc appropriately classifiable under CTI1 73089090 or 73269060.

3.(D) Judicial pronouncements: Further, applicant informed that Identical goods are being allowed to be cleared by the JNCI I, Nhava Sheva under CTII 73089090 or 73269060.

Port of Import and reply from jurisdictional Commissionerate:

4. The applicant in their CAAR-1 indicated that they intend to import the subject goods from^–the jurisdiction of Office of the Commissioner of Customs, Nhava Sheva-II .INCI 1, Fah: Uran. ‘Me application was forwarded to the Office of the Commissioner of Customs, Nhava Sheva-Ill, JNCI I, Tal: Uran, Distt. – Raigad for their comments on 29.10.2025, 28.11.2025 however, no reply has been received in this regard.

5. Details of Personal Hearing:

5.1 A personal hearing was held on 27.11.2025 at 1:30 pm. I,earned Advocate Shri Ash \van i Kumar Prabhakar along with Shri Yash Jain authority I ‘older of the firm appeared Ibr the hearing on behalf of applicant. rrhey reiterated the contentions filed with the application. ‘they submitted that the subject goods ^—Architectural Decorative Designer Wall Panel Articles of Stainless Steel” of different shapes. sizes and finishes with or without drilled holes^– in corners. They contended that the product merit classification under CTEI 73269060 or CTI 73089090. They also referred that the identical goods arc also being imported under both the heading 73269060 and 73089090. They further contended that the structure is specifically designed and from integral and immovable part of^–built environment.

No body attended for PI 1 from the department side.

6. DISCUSSION AND FINDINGS

6.1 I have, carefully examined the application filed by the Applicant, the written submissions made in support thereof, the product descriptions, photographs, manufacturing process, and other documents placed on record. I have also considered the oral submissions made by the Id. Advocate and authorised representative during the personal hearing dated 27.11.2026. Further. 1 have examined the relevant provisions of’ the Customs Act, 1962. the First Schedule to the Customs Tariff Act, 1975, the General Rules for the Interpretation of the Import Tariff (GIR), the llarmonised System of Nomenclature (I1SN) Explanatory Notes and the settled principles of tariff classification.

6.2 The issue for determination in the present application is as under:

“Whether the goods proposed to he imported, described as “Architectural Decorative Designer Wall Panel Articles of Stainless Steel of different shapes. sifes widlinishes with or without drilled holes in corners”, are classifiable under Customs Thrill heading 7308 90 90 or 7326 90 60, as claimed by the Applicant, or under other Customs Thrill !leading under CM 7219 _.for example under CTII 7219 90 90 of The First Schedule to the Customs ThriffAct, 1975.”

6.3 I observe that the Applicant has restricted the question for advance ruling to classification under I leadings 7308 and 7326. However, it is a settled position of law that the Authority for Advance Rulings is not bound by the tariff headings suggested by the Applicant and is required to determine the correct classification in accordance with the Customs Tariff Act. 1975, the General Rules for Interpretation and existing legal positions in terms of relevant case laws.

6.4 On examination of the records, I find that the subject goods are manufactured from flat-rolled stainless-steel sheets. These sheets arc cold-rolled and thereafter subjected to cutting to size and various surface finishing processes such as mirror polishing, hairline finish, satin finish. embossing. etching, vibration finish, sand blasting, anti-fingerprint coating and Physical Vapour Deposition (PVI)) coating. Protective PVC film is applied to prevent surface damage during transportation and handling.

6.5 I find that the goods arc imported in the form of flat panels of stainless-steel having uniform thickness, ranging approximately from 0.4 mm to 3 mm, and supplied in rectangular, square. circular or triangular shapes. Notwithstanding the surface finishing and decorative treatments, the _essential character of the goods remains that of flat-rolled stainless-steel products.

6.6 Heading 7219 of the Customs Thriff covers “Flat-rolled products of stainless steel, of a width of 600 mm or more”. At this stage. it is relevant to reproduce the statutory and explanatory provisions governing Chapter 72.

Note 1(k) to Chapter 72 defines “flat-rolled products” as follows:

Flat-rolled products:

“Rolled products of solid rectangular (other than square) cross-section, which do not conform to the definition at (if) above in the form of

– coils qf successively superimposed layers, or

– straight lengths, which if qfa thickness less than 4.75 mni are ()fa width measuring at least ten times the thickness or if of a thickness of 4.75 mm or more are of a width which exceeds 150 mm and measures at least twice the thickness.

Flat-rolled products include those with patterns in relief derived directly from rolling (far example, grooves, ribs, chequers, tears, buttons, lozenges) and those which have been perforated, corrugated or polished, provided that they do not thereby assume the character of articles or products of other headings.

Hat-rolled products of a shape other than rectangular or square, of am size, are to he classified as products of a width of 600 n7177 or more, provided that they do not assume the character of articles or products of other headings.

Further, the I ISN Explanatory Notes to Chapter 72 (General Explanatory Note Subsequent Manufacture and Finishing) specifically provide that:

“The finished products may be subjected to further finishing treatments or converted into other articles by a series of operations such as mechanical working (e.g.. perfbration or punching) or surface treatments including coating. cladding. polishing or similar processes to improve the properties or appearance of the metal, protect it against rusting or corrosion. etc.^–The Explanatory Notes further clarify that such finishing operations do not affixt classification so-long as the products retain the character of flat-rolled products.

6.7 I find that the various surface finishing processes applied to the subject goods. including mirror polishing, embossing, etching, PVD coating, anti-fingerprint coating and PVC lamination. merely enhance their appearance. corrosion resistance and durability. These processes do not bring into existence a new product having a distinct name, character or use. nor do they alter the fundamental identity of the goods as flat-rolled stainless-steel products. The applicant has claimed that the subject goods provide weather resistance and create a modern architectural decorative appearance.

This legal position stands fortified by judicial precedents. In Zaverchand Gaekwad Pvt. Ltd. V/s Union of India 1^–1992 (61) E.L.T. 225 (Guj.)1, the lIon’ble Gujarat High Court held that galvanisation of steel does not amount to manufacture, as the basic character of steel remains unchanged.

Similarly, the flon’ble Supreme Court. in the matter of Metlex (I) Pvt. Ltd. V/s Commissioner of Central Excise, New Delhi 2004(165) ELI 129(S.C.) observed that lamination or metallising processes do not result in emergence of a new product, as such processes merely improve surface characteristics without changing the essential identity of the goods.

The ratio of the above decisions applies squarely to the present case and supports the conclusion that surface finishing and decorative treatments cannot take flat-rolled stainless-steel products out of Chapter 72.

6.8 I now examine the applicability of I leading 7308. I leading 7308 covers structures an6 parts of structures of iron or steel. As clarified in the I ISN Explanatory Notes, this heading applies to goods which are identifiable as structures or parts of structures performing a structural or constructional function. I find that the subject goods arc not beams, .columns, frames. trusses or other structural components. Mere use of flat stainless-steel sheets for cladding or decorative applications on walls. facades or interiors does not render them parts of structures for the purpose of I leading 7308. Accordingly, classification under !leading 7308 90 90 is not tenable.

6.9 I further examine I leading 7326, which is a residuary heading covering “Other articles of iron or steel”. This heading applies only when goods arc not more specifically covered elsewhere. In the present case. I find that the subject goods arc specifically described unde: H eading 7219. Therefore, classification under I leading 7326 90 60 is also not sustainable.

6.10 Applying Rule I of the General Rules for Interpretation. classification is to be determined according to the terms of the headings and the relevant Section and Chapter Notes. As the subject goods arc flat-rolled products of stainless steel, they are squarely classifiable under I leading 7219. The application of Rule 3 does not arise in the present case. Applying Rule 6 at the sub-heading level, the appropriate classification is under Customs Tariff I leading 7219 90 90.

6.11 In view of the foregoing discussion, I find that the goods proposed to be imported by the Applicant are correctly classifiable under Customs TarifIlleading 7219 90 90 and not undo^–I loadings 7308 or 7326 as claimed by the Applicant.

RULING

7. I rule that the goods described as “Architectural Decorative Designer Wall Pane! Articles of Stainless Steel of different shapes. sizes and Finishes with or without drilled holes in corners” arc classifiable under Customs Tariff 1leading 7219 90 90 as “Other flat-rolled products of stainless steel”.

I rule accordingly.