Classification of Magnesium Bis-glycinate Chelate: CAAR Mumbai Rules in Favour of CTH 2922
The Customs Authority for Advance Rulings, Mumbai has provided an important clarification on customs tariff classification of Magnesium Bis-glycinate Chelate imported in bulk as an ingredient for nutritional products. By Ruling No. CAAR/Mum/ARC/51/2026-27 dated 27.07.2026 in In re Inhalation Health Private Limited (CAAR Mumbai), the Authority concluded that the product is correctly classifiable under CTH 2922 49 90 and not under Heading 2106 as a food preparation.
This ruling gives valuable guidance to importers dealing with amino acid–based mineral chelates and similar chemically defined substances, particularly where such goods are used as raw materials for nutraceuticals or dietary supplements.
Background of the Advance Ruling Application
Applicant and Nature of Transaction
M/s. Inhalation Health Private Limited approached the Customs Authority for Advance Rulings, Mumbai under Section 28-I(1) of the Customs Act, 1962. The assessee proposed to import Magnesium Bis-glycinate Chelate through JNCH, Nhava Sheva, and sought an advance ruling on the appropriate customs tariff heading for the product.
The advance ruling mechanism was invoked to secure certainty in classification, given that classification directly affects the rate of customs duty and related compliance obligations.
Description and Composition of the Product
The product that was the subject of the ruling is Magnesium Bis-glycinate Chelate. As per the applicant’s submissions, the composition is broadly as follows:
- Magnesium Bis-glycinate Chelate: more than 79%
- Citric Acid: less than 11%
- Water: not more than 10%
From a chemical perspective, the assessee described the product as a coordination compound represented by the formula C4H8MgN2O4, comprising one magnesium ion bonded to two molecules of glycine (an amino acid). The magnesium ion is chelated by the amino and carboxyl functional groups of glycine.
The assessee clarified that:
- Citric acid is added only to stabilize the compound.
- The goods are imported in bulk form.
- The intended use is as a raw material for manufacturing nutritional or dietary supplements, and not as a finished consumer product.
Classification Dispute: CTH 2922 vs Heading 2106
Applicant’s Stand on Tariff Heading
The assessee argued that Magnesium Bis-glycinate Chelate is a chemically defined coordination compound whose organic component is glycine, an amino acid. On this basis, the product was claimed to be classifiable under:
- Heading 2922 – “Oxygen-function amino-compounds”
- More specifically, CTH 2922 49 90 – “Other” amino-acids and their esters; salts thereof
To support this position, the assessee relied on:
- Chapter Note 5(C)(3) to Chapter 29 dealing with classification of coordination compounds, and
- Chapter Note 1(d) and 1(f) to Chapter 29, which allow for certain additions such as water and stabilizing agents without altering the classification of a chemically defined compound.
The assessee strongly opposed classification under Heading 2106, contending that:
- The product is not a “food preparation” but a single chemically defined compound.
- It is not a finished supplement, but only a bulk ingredient used in manufacturing nutritional products.
- Classification cannot be shifted to a residual heading like 2106 merely because the substance ultimately enters the food or nutraceutical chain.
Lack of Departmental Response
The jurisdictional Commissionerate was asked to offer its comments on the application. However, the Authority recorded that no response was received from the Department.