In re OPPO Mobiles India Private Limited (CAAR Delhi)
Summary: The Customs Authority for Advance Rulings, Delhi considered M/s OPPO Mobiles India Private Limited’s application seeking an Advance Ruling on the classification of a proposed import described as a “back cover assembly with battery” for tablet PCs. The application was received on 07.04.2026 under Section 28-H of the Customs Act, 1962. The applicant proposed classification under CTH 8473 30 99, treating the assembly as a composite part of an automatic data processing machine. The jurisdictional Commissionerate contended that the assembly was classifiable under CTH 8507.
The proposed assembly comprises eleven components: middle frame, camera lenses, flash lens, conductive cloth, thermal conductive pads, plastic bracket, waterproof label, plastic sleeve for the power key, self-adhesive foam sheets, a lithium-ion battery and back cover. The applicant stated that the assembly provides structural accommodation and fixation, protection from impact and dust, power supply and heat dissipation, and is intended for use with tablet PCs. The applicant relied on the Customs Tariff Act, 1975, the General Rules for Interpretation and Section XVI Note 2(b), contending that the integrated battery was only one component of a composite article whose essential character was structural.
The jurisdictional Commissionerate disagreed. It relied on Section XVI Note 2(a), the exclusion of “covers, carrying cases and the like” from heading 8473, the General Explanatory Note to Section XVI concerning electric accumulators assembled into battery packs, and the Explanatory Note to heading 85.07. It submitted that the lithium-ion battery was specifically covered by heading 8507 and that Note 2(a) had to be applied before any essential-character exercise under GRI 3(b). It also noted that no component-wise value or weight break-up had been furnished to support the applicant’s essential-character claim.
