In re Samsung India Electronics Private Limited (CAAR Mumbai)
In Customs Authority for Advance Rulings, Mumbai, the applicant sought an advance ruling on the correct customs classification of “Resonator – Ceramic” proposed to be imported for use in electronic control boards of appliances such as washing machines. The product is a ceramic resonator made from Lead Zirconium Titanate (PZT), a recognised piezoelectric material, fitted with inner electrodes, solderable terminals, and epoxy encapsulation. It functions as an electronic oscillator by converting mechanical resonance into a stable electrical oscillation of a defined frequency, which serves as a clock signal for microprocessors where high frequency accuracy is not critical.
The applicant contended that the product is classifiable under Customs Tariff Item (CTI) 8541 60 00 as “mounted piezo-electric crystals.” Alternative classifications under CTI 8543 (electrical machines and apparatus having individual functions), CTI 8548 (residuary electrical parts), or as parts of washing machines under CTI 8450 were examined and opposed by the applicant.
The jurisdictional Commissionerate examined the product’s material composition, electrical characteristics, and functionality and concurred with classification under Heading 8541. It was noted that Heading 8541 expressly covers mounted piezoelectric crystals, including those based on ceramic materials such as lead titanate zirconate, provided they are equipped with electrodes or electrical connections. The resonator was found to be a finished, mounted electronic component ready for surface-mount assembly, and not an unworked ceramic or a generic part of a washing machine.
