F.No. 528/21/2018-STO (TU)
Government of India
Ministry of Finance
Department of Revenue
(Central Board of Indirect Taxes 86 Customs)
North Block, New Delhi
All Principal Chief Commissioners/Chief Commissioners of Customs/Customs (Preventive)
All Principal Chief Commissioners/Chief Commissioners of Customs and GST
All Principal Commissioners/Commissioners /Customs (Preventive)
Subject: Classification of e-seals – reg.
It has been brought to the attention of the Board that the RFID e-seals for sealing of containers are being classified variably at different locations.
2. The issue of classification of RFID seals was referred to the Board and it has been examined with respect to the functionality, SAFE framework standards provided by WCO regarding various kinds of seals (including e-seals) and the HSN Explanatory Notes.
3. According to the current ISO 181852 definition, an e-seal is a “Read-only, non-reusable freight container seal conforming to the high security seal defined in ISO/PAS 17712(standard for mechanical seals) and conforming to ISO 18185 or revision thereof that electronically evidences tampering or intrusion through the container door”.
4. It is amply clear from the above that electronic seals are seals only but with electronic add on (RFID) to detect security breach. Therefore, e-seals merit classification under the Heading 8309 which covers- Stoppers, caps and lids (including crown corks, screw caps and pouring stoppers), capsules for bottles, threaded bungs, bung covers, seals and other packing accessories, of base metal. As seals are specifically mentioned there, e-seals warrant classification under the tariff item 8309 90 30.
5. All assessment are to be done accordingly.
6. Difficulties, if any, in the implementation, should be brought to the notice of the Board.