In re ATL Battery Technology (India) Private Limited (CAAR Delhi)
The Customs Authority for Advance Rulings (CAAR), Delhi examined an application seeking classification and eligibility for concessional customs duty of thirteen products proposed to be imported for use in the manufacture of lithium-ion cells. After examining the CAAR-1 application, comments from the jurisdictional Customs Commissionerate, records of personal hearing, additional submissions, and the applicable legal framework, the Authority found the application valid under the Customs Act, 1962 and CAAR Regulations, 2021, and proceeded to determine the classification of the proposed imports.
The products under consideration included various self-adhesive plastic tapes, polymer additives, binders, cellulose derivatives, silicones, and synthetic rubber latex. These items were described as essential inputs used at different stages of lithium-ion cell manufacturing, such as improving mechanical stability, acting as electrolyte additives, serving as binders for cathode and anode slurries, and stabilising dispersions.
The Authority applied the General Rules for Interpretation (GRI), particularly Rule 1, which mandates classification based on the terms of headings and relevant Section and Chapter Notes. Each product was examined individually with reference to the relevant tariff headings under Chapter 39 and Chapter 40 of the Customs Tariff Act, 1975, along with HSN Explanatory Notes.
The various self-adhesive tapes made of polypropylene with hot-melt pressure-sensitive adhesive were found to satisfy the conditions of Heading 3919, as they were self-adhesive flat plastic shapes, pressure-sensitive, imported in rolls not exceeding 20 cm in width. Accordingly, these tapes were classified under tariff item 3919 10 00.
Polyether-modified polysiloxane, used as an electrolyte additive, was held to be classifiable under Heading 3910 as “silicones in primary forms,” as its chemical structure was based on a silicon-oxygen backbone, despite being polyether-modified.
POLYSOL LB-150J, consisting of styrene acrylate copolymer in aqueous emulsion form and used for adhesive applications, was classified under tariff item 3903 90 90 as a styrene-based polymer.
PVDF (polyvinylidene fluoride), used as a binder for cathode slurry, was held classifiable under tariff item 3904 69 90 as a fluoropolymer.
The additive Ethylpyrrolidone–Acrylate copolymer NMP solution, used as a binder for anode slurry, was classified under tariff item 3906 90 90, as it was an acrylic polymer in primary form.
Lithium Carboxymethyl Cellulose and Sodium Carboxymethyl Cellulose were found to be chemically modified cellulose derivatives. Since both were salts of carboxymethyl cellulose, they were classified under tariff item 3912 31 00, which specifically covers carboxymethyl cellulose and its salts.
Binder-SN-307R Styrene-Butadiene copolymer (SBR), a synthetic rubber latex used as an anode slurry binder, was classified under tariff item 4002 11 00.
The Authority further examined whether the thirteen items were eligible for concessional duty under Notification No. 45/2025-Customs dated 24.10.2025 (superseding Notification No. 50/2017-Customs), subject to compliance with the Customs (Import of Goods at Concessional Rate of Duty or for Specified End Use) Rules, 2022 (IGCR). It was noted that all thirteen items were directly integrable into the lithium-ion cell production line and were unequivocally inputs, parts, sub-parts, or raw materials used in the manufacture of lithium-ion cells classifiable under tariff item 8507 60 00.
Relying on the wording of the notification, its chapter-neutral scope, and the functional role of the goods, the Authority concluded that the benefit of concessional duty under the notification was available to all thirteen items, subject to strict compliance with the IGCR procedure and actual end-use in lithium-ion cell manufacturing.
The advance ruling was issued accordingly.
FULL TEXT OF THE ORDER OF CUSTOMS AUTHORITY OF ADVANCE RULING, DELHI
