In re Rashi Peripherals Limited (CAAR Mumbai)
The application before the Customs Authority for Advance Rulings (CAAR), Mumbai, concerned the classification of the “Oura Health Ring/Smart Ring” and its associated “Sizing Kit” under the Customs Tariff Act, 1975. The applicant sought classification under Tariff Item 90318000 for the Smart Ring and either 90318000 or 90319000 for the Sizing Kit.
The Smart Ring is a wearable, non-invasive health and wellness device designed as a finger ring and made of titanium. It incorporates various sensors such as an accelerometer, temperature sensor, and LEDs for photoplethysmography (PPG) to continuously measure physiological parameters. These include sleep-related metrics, heart rate, temperature, activity levels, and women’s health indicators. The device does not have a display and transmits collected data to a mobile application via Bluetooth, where the data is analyzed and presented. The Bluetooth functionality is limited and ancillary, as it is used only for syncing data and updates, and the device does not independently perform communication functions such as calling or messaging.
The applicant argued that the product’s primary function is measurement of physiological parameters and that it qualifies as a “measuring or checking instrument” under Heading 9031. It was further contended that the product is not covered elsewhere in Chapter 90 and does not fall within any exclusion under the HSN explanatory notes. The applicant also relied on prior advance rulings and international rulings classifying similar smart rings and fitness trackers under Heading 9031. Additionally, it was submitted that classification cannot be determined based on exemption notifications, and Bluetooth connectivity does not make the product a communication device under Heading 8517.
