In re Clarion India Private Limited (CAAR Delhi)
The case at hand involves the classification of various components, such as LCD panels, touch screens, and printed circuit boards (PCBs), used in automotive infotainment systems under the Customs Tariff. The applicant imports LCD panels for assembly into car audio systems, which are then integrated into vehicles by original equipment manufacturers. The LCD panels, which function as flat panel display modules, are classified under tariff heading 8524, specifically as a part of the infotainment system for motor vehicles. These panels meet the criteria of a “flat panel display module,” including features like display screens, integration with other devices, and lack of signal conversion components. As per the General Rules of Interpretation and HSN Explanatory Notes, LCD panels not combined with other apparatus but used in vehicles are appropriately classified under Heading 8524.
In addition, the case considers touch screens, which are integral parts of the LCD panels in the infotainment systems. The ruling aligns touch screens with tariff Heading 8529 as parts suitable for use with the flat panel display modules under Heading 8524. The classification is based on Section Note 2 of Section XVI, which designates parts of goods under Chapter 85, ensuring the touch screen is properly classified as an accessory. Lastly, the printed circuit boards (PCBs) used in these systems are classified under Heading 8534 as printed circuits, meeting the necessary criteria of being formed with conductor elements and contacts, without any active electronic components like semiconductors. The ruling also clarifies the applicability of anti-dumping duties on PCBs imported from China, noting that these goods are subject to duties as per the ADD notification effective from March 2024.
