In re QIAGEN India Private Limited (CAAR Delhi)
QIAGEN India Private Limited, a wholly owned subsidiary of QIAGEN GmbH, Germany, engaged in manufacturing and supplying diagnostic reagents, kits, and instruments, filed an application dated 18.12.2024 before the Customs Authority for Advance Rulings, Delhi (CAAR) under Section 28H of the Customs Act, 1962, seeking clarity on classification of imported items, specifically “QIAshredder (50).” The application was registered as Serial No. 32/2024 dated 18.12.2024.
The company imports various diagnostic reagents, kits and instruments through Indira Gandhi International Airport, New Delhi. QIAshredder was described as a cell-lysate homogenizer and filter used in nucleic acid minipreps, operating through a centrifugation process to remove/filter cell debris and simultaneously homogenize lysate using a biopolymer-shredding system in a microcentrifuge spin-column format. The lysate is loaded into the spin-column placed in a collection tube and centrifuged, after which homogenized lysate is collected. It is used with RNeasy Mini Kit, RNeasy Protect Mini Kit and RNeasy Plant Mini Kit for sample preparation to ensure better RNA yields and prevent sample wastage.
The applicant sought a ruling on whether QIAshredder is classifiable under CTH 84212900 as “Other filtering or purifying machinery and apparatus for liquids.” The applicant asserted eligibility under Section 28E(c)(i) due to holding a valid IEC (0510019731) and stated that the matter was not pending or decided elsewhere, hence not barred under Section 28I.
The applicant relied on General Rules for Interpretation, HSN Explanatory Notes, and cited Supreme Court rulings on HSN usage, arguing QIAshredder is a filtering device with a membrane used to filter liquid lysates and therefore fits within CTH 84212900.
The concerned Customs Port Commissionerate provided comments dated 23.08.2025 stating the applicant was eligible, no dispute was pending, the nature of activity appeared correct, and classification would be under CTH 84219900.
The applicant later submitted additional submissions on 13.11.2025 stating it had earlier classified the goods under CTH 38229090 at 30% duty, but approached CAAR for confirmation and emphasized that QIAshredder is a machine in itself, not a part.
Personal hearings were held on 26.08.2025 (physical) and 17.11.2025 (virtual). CAAR examined the application, submissions, port comments, and hearing records, found the application valid, and identified the competing entries as CTI 84212900 versus 84219900.
CAAR noted QIAshredder does not operate independently, has no mechanical/electrical/electronic components, no power source or moving parts, and functions only when centrifugal force is applied by an external centrifuge. It was held to be a specially designed plastic column with an internal membrane that becomes operative only as a component fitted into another machine.
CAAR applied Section Note 2(b) of Section XVI and concluded QIAshredder is used with centrifuges under heading 8421 and thus warrants classification as parts under CTI 84219900.
Accordingly, CAAR ruled that QIAshredder is not classifiable under CTI 84212900 and is rightly classifiable under Tariff Item 84219900 of the Customs Tariff Act, 1975.
FULL TEXT OF THE ORDER OF CUSTOMS AUTHORITY OF ADVANCE RULING, DELHI
