In re Danisco India Pvt. Ltd. (CAAR Delhi)
M/s Danisco India Pvt. Ltd. filed an application before the Customs Authority for Advance Rulings, Delhi seeking an advance ruling on the classification of a proposed import named “Linum Life®” under the Customs Tariff Act, 1975. The application was received on 15 May 2025 and was made under Chapter V-B of the Customs Act, 1962, which governs advance rulings. The applicant held a valid Importer-Exporter Code and confirmed that the issue of classification was not pending or decided in any other proceedings, making the application maintainable.
The product proposed for import, Linum Life®, was described as a plant-based extract derived from flaxseed (Linum usitatissimum). It is obtained by solvent extraction using ethanol and subsequently converted into a brown-beige powder with the addition of potato maltodextrin as a carrier. The applicant stated that maltodextrin is an inert substance added only to facilitate conversion into powder form and improve handling and transport. The product is imported in bulk and supplied to industrial customers, who use it as a raw material in the manufacture of functional foods and dietary supplements. It is not sold in retail packs or consumed directly.
The applicant sought classification under Tariff Item 13021919, which falls under Heading 1302 covering “vegetable saps and extracts.” Detailed submissions were made with reference to the General Rules for Interpretation, Section and Chapter Notes, and the Harmonized System Explanatory Notes. The applicant contended that Linum Life® is a simple vegetable extract, obtained from a single plant variety through solvent extraction, presented in solid form, and remaining a raw material for further manufacture. It was emphasized that the addition of inert substances like maltodextrin does not alter the essential character of the extract or remove it from Heading 1302.
