In re FMC India Private Limited (CAAR Mumbai)
The ruling concerns an advance ruling application filed before the Customs Authority for Advance Rulings (CAAR), Mumbai regarding the appropriate customs tariff classification of two imported chemicals—Cyantraniliprole and Clothianidin. The application was filed on 29 September 2025 under Section 28FI(1) of the Customs Act, 1962. The applicant, an Indian company engaged in manufacturing agrochemicals and formulations, imports certain chemicals used as raw materials in the production of insecticides.
The applicant imports Cyantraniliprole and Clothianidin in technical-grade form in 200 or 226-liter metal drums. These substances are active chemical ingredients used in the manufacture of insecticides. After importation, the chemicals are diluted with solvents such as water or hydrocarbons and mixed with other ingredients to produce formulated insecticides. The applicant had historically classified these chemicals under Chapter 38 of the Customs Tariff as insecticides. However, following amendments made to the Customs Tariff Act through the Finance Act, 2025, the applicant believed that the chemicals should instead fall under newly introduced entries in Chapter 29, which deals with organic chemicals.
The applicant therefore sought clarification on whether Cyantraniliprole and Clothianidin should be classified under tariff headings 29333923 and 29341010 respectively under Chapter 29, rather than under Heading 3808 covering insecticides and similar products.
