Electric Vehicle Communication Controller (EVCC) Classifiable as Communication Equipment Under Tariff Item 8517 62 90 — CAAR Delhi
Background and Context
The Customs Authority for Advance Rulings (CAAR), New Delhi, recently delivered a significant ruling in the matter of M/s Solterra Technologies Pvt Ltd, a company incorporated under the Companies Act, 2013, having its registered office at Ground Floor, 12/74, Pioneer Complex, Site-4, Industrial Area, Sahibabad, Ghaziabad — 201010. The company is engaged in manufacturing electric chargers for two-wheeled and three-wheeled electric vehicles and also imports various components including rectifiers and Supply Equipment Communication Controllers (SECC) under CTI 8504 90 90.
The applicant filed a formal application in Form CAAR-1 before CAAR, New Delhi, which was received on 09.12.2025, pursuant to Section 28H(1) of the Customs Act, 1962. The core subject matter revolved around the correct customs classification of Electric Vehicle Communication Controllers (EVCC) — components imported by the applicant from a supplier based in the Republic of Korea — and the eligibility of these goods for preferential duty benefits under applicable trade agreement notifications.
Questions Referred for Advance Ruling
The applicant placed the following specific questions before the CAAR, New Delhi:
Q1: Whether the EVCC proposed to be imported qualifies for classification under CTI 8517 62 90 or CTI 8708 90 99 of the First Schedule to the Customs Tariff Act, 1975?
Q2: If the EVCC does not merit classification under either of the above tariff items, what is the appropriate classification under the First Schedule to the Customs Tariff Act, 1975?
Q3: Whether the applicant is eligible to avail customs duty exemption under Notification No. 151/2009-Customs and Notification No. 152/2009-Customs, both dated 31st December, 2009, in cases where the HSN code appearing on the Proof of Origin (POO) differs from the HSN code declared in the Bill of Entry (BoE), even though the physical goods are identical in all material respects?
Understanding the Functional Architecture of the EVCC
What Does the EVCC Do?
The EVCC is a dedicated communication device installed within an electric vehicle (EV). Its primary role is to facilitate structured and protocol-compliant data exchange between the EV and the Electric Vehicle Supply Equipment (EVSE), i.e., the charging station. The device operates in accordance with internationally recognised standards — specifically DIN SPEC 70121 and ISO 15118 — which govern the Combined Charging System (CCS) protocol.
In practical terms, the EVCC functions as the communicative nerve centre of the EV during the charging process. It receives incoming signals, processes and converts data aggregated from various subsystems of the vehicle, and transmits the prepared data to the SECC embedded in the charging station.
Step-by-Step Communication Sequence
The EVCC's operation during a charging session can be broken down as follows:
Step 1 — Signal Transmission from Charging Cable:
- When Mr. Sharma (a representative EV user) connects the charging cable to the vehicle inlet, the cable's Proximity Pilot (PP), Control Pilot (CP), and Protective Earth (PE) pins become active.
- The resistor between PP and PE generates a specific voltage level that communicates the cable's current-handling capacity.
- Simultaneously, the CP pin transmits Pulse Width Modulation (PWM) signals to the EVCC, indicating the permissible current draw from the EVSE.
Step 2 — Signal Reception by the EVCC:
- The EVCC reads the voltage generated across PP and PE to confirm plug connection and identify the cable's current rating.
- It simultaneously interprets the PWM signals from the CP line to determine the allowable current draw.
- Once both signals are successfully received, the EVCC confirms that the plug is connected and charging may commence.
Step 3 — Internal System Activation and Data Transmission:
- Upon successful handshake, the CAN Bus within the EV aggregates data from subsystems including the Battery Management System (BMS), onboard charger, and vehicle status modules.
- This data encompasses parameters such as State of Charge (SoC), maximum permissible charging power, and temperature readings.
- The EVCC acts as a central bridge, interpreting this aggregated data and structuring it for external communication with the SECC in the charging station.
- Communication with the EVSE is carried out through Power Line Communication (PLC), compliant with ISO 15118 or DIN SPEC 70121, over the CP line.
- Charging parameters including voltage, current, and SoC are dynamically exchanged every few seconds during the session.
Core Functional Summary
Based on the above operating mechanism, the principal functions of the EVCC can be consolidated as:
- Reception: The EVCC receives voltage levels and PWM signals from the charging cable connected to the EVSE.
- Conversion: Through the CAN Bus, the device collects data from various EV subsystems and converts it into analogue signals suitable for transmission over the CP Line.
- Transmission: The converted signals are transmitted to the SECC in the charging station via the CP Line using PLC protocol.