Classification of Thermal Putty for Mobile Phone Manufacturing: CAAR Delhi Ruling

In re Vivo Mobile India Pvt Ltd. (CAAR New Delhi)

M/s. Vivo Mobile India Pvt. Ltd. has sought an advance ruling from the Customs Authority for Advance Rulings, New Delhi (CAAR) regarding the classification of Thermal Putty used in manufacturing mobile phones. This article delves into the detailed analysis of the issue and the ruling provided by CAAR New Delhi.

1. Classification of Thermal Putty:

• The applicant imports Thermal Putty for use in manufacturing mobile phones, primarily for its thermal conductivity and heat dissipation properties.
• Thermal Putty acts as a heat conduction medium between microchip positions, preventing damage due to heat generated by the CPU.
• Its composition includes alumina, zinc oxide, and various siloxanes, contributing to its thermal transfer and stress-relieving capabilities.

2. Competing Tariff Headings:

• The applicant seeks classification under Sub-heading 38249900, covering chemical products not elsewhere specified or included, for tariff exemption.
• The alternative classification is under Sub-heading 32149090, which includes various putty types but may not accurately represent Thermal Putty’s functionality.

3. Legal Interpretations:

• The applicant argues for classification under Heading 3824 based on the chemical composition and functionality of Thermal Putty.
• They cite US CROSS Ruling NY HQ 952979 to support their claim that similar thermal conductive products fall under chemical preparations categories.

4. Application Admissibility:

• CAAR New Delhi examines the admissibility of the application under Section 28E of the Customs Act, finding it eligible for an advance ruling.
• The ongoing nature of the activity and lack of prior dispute or settlement support the admissibility of the application.

Conclusion: