HL Mando Anand India Pvt Ltd (CAAR Mumbai)
The Customs Authority for Advance Rulings, Mumbai, examined an application filed by HL Mando Anand India Pvt Ltd seeking classification of the imported product “Integrated Dynamic Brake” (iDB). The applicant imports the product without further processing and resells it. The iDB is an electro-hydraulic braking system integrating multiple components such as sensors, ECU, motor, pump, piston, reservoir, and valve block into a single unit that regulates braking force and enhances vehicle safety and performance.
The applicant argued that the product should not be classified under Customs Tariff Heading (CTH) 8708 (parts of motor vehicles), particularly sub-heading 8708 3000 (brakes and parts thereof). It contended that the iDB is not an essential part of braking because the mechanical braking system can function independently even if the iDB fails. Instead, it was claimed to be an advanced system that enhances braking efficiency through automation and regulation.
Based on this reasoning, the applicant proposed classification primarily under CTH 9032 as an automatic regulating or controlling apparatus, asserting that the iDB meets the criteria of measuring, controlling, and operating devices under Note 7(a) of Chapter 90. Alternatively, it proposed classification under CTH 8413 (pumps), arguing that the essential character of the product is pumping brake fluid, or under CTH 8479 as a residual category for machines with individual functions not specified elsewhere.
