CAAR Mumbai Ruling: Proper Customs Classification of Pine Bark and Grape Seed Extracts Under CTH 1302

The Customs Authority for Advance Rulings (CAAR) situated in Mumbai recently addressed a critical classification dispute concerning botanical raw materials. In the matter of In re JESSP Chemicals (CAAR Mumbai), the authority evaluated the appropriate tariff heading for imported Pine Bark Extract and Grape Seed Extract. The ruling provides essential clarity on distinguishing between basic vegetable extracts and prepared food supplements under the Customs Tariff Act, 1975.

Background of the Advance Ruling Application

The assessee, M/s JESSP Chemicals, approached the CAAR to seek certainty on the customs classification of two specific products: Pine Bark Extract and Grape Seed Extract. These goods were being imported in bulk to serve as raw materials for the domestic nutraceutical manufacturing industry.

The primary contention revolved around two competing tariff headings:

  • Heading 1302: Pertaining to vegetable saps and extracts.
  • Heading 2106: A residual heading generally covering food preparations not elsewhere specified or included.

The assessee asserted that the imported goods rightfully belonged under CTH 1302 as they were fundamentally vegetable extracts.

The Revenue Department's Contention