Foam Production Line Treated as Injection Moulding Machine: CAAR Mumbai Ruling Explained

1. Background of the Advance Ruling

In re Adient India Private Limited (CAAR Mumbai) concerns an application filed under Section 28H(1) of the Customs Act, 1962 before the Customs Authority for Advance Rulings, Mumbai. The assessee sought an advance ruling on:

  • Customs tariff classification of “Foam Production Line with 32 Station Conveyors (including Dry Side and Metering Machine) (Part No. CAP0003805)” proposed to be imported from China in CKD/SKD form; and
  • Applicability of anti-dumping duty (ADD) under Notification No. 21/2025-Customs (ADD) dated 26.06.2025.

The assessee, a manufacturer of automotive seat systems for major OEMs, intended to import a complete foam manufacturing line from Krauss Maffei Machinery (China) Co. Ltd.. All components necessary to set up the machine were to be brought in completely knocked down (CKD) or semi knocked down (SKD) condition and presented together for customs clearance at Nhava Sheva.

The Authority examined both the technical configuration of the machine and the applicable legal framework — primarily Heading 8477, relevant General Rules for Interpretation (GRI), and the terms of the ADD notification.

2. Technical Description of the Foam Production Line

2.1 Broad Configuration

The imported system is an integrated polyurethane foam production line, consisting of two major functional assemblies:

  1. Metering Machine
  2. Dry Side (32 Station Conveyor System with Mould Carriers)

Both sub-systems operate together as a single production unit to manufacture polyurethane foam (PUR) seat components.

2.2 Metering Machine – Chemical Storage, Metering, and Mixing

The metering machine incorporates:

  • Four day tanks of 500 litres each
  • High pressure metering pumps
  • Mixing heads
  • Hydraulic pumps
  • Electrical and electronic control units (PLC, HMI, switchgear)
  • Ancillary electromechanical devices (heat exchangers, flow meters, level sensors, pressure transducers, etc.)

Process flow is as follows:

  1. Chemical Storage

    • Three day tanks hold different types of polyol.
    • One day tank stores isocyanate.

  2. High Pressure Metering

    • Each day tank is connected through pipelines to a dedicated high-pressure metering pump.
    • These pumps circulate the chemicals at about 150 bar.

  3. Mixing Operation

    • Each high-pressure pump feeds two mixing heads.
    • The mixing heads are hydraulically operated and mounted on robots.
    • Pre-determined quantities of polyol and isocyanate are mixed in the mixing head to create the PUR-forming mixture.

  4. Robotic Dispensing

    • Each mixing head is attached to a robot.
    • The robot automatically pours (injects) the reactive mixture into the moulds located on the conveyor carriers.

  5. Control & Safety

    • PLC and HMI units regulate chemical temperature, flow, and process safety through interlocks.

2.3 Dry Side – Conveyor, Mould Carriers and Clamping

The “dry side” is essentially the mould handling and curing section, consisting of:

  • 32 mould carriers mounted on an oval conveyor
  • Gear box, drive chain and mechanical steel structure for the oval path
  • Water heating units installed on the racetrack and travelling with the carriers
  • Clamping mechanism providing 80 kN force (approximately 8.02 tonnes) per station

Operationally:

  1. Each of the 32 carriers can hold moulds weighing up to 700 kg.
  2. The carriers move continuously along an oval conveyor at 10–12.5 m/minute, controlled by PLC/HMI.
  3. At the pouring station, the robot dispenses the PUR mixture into the open mould on a carrier.
  4. The mould is then closed and clamped by the carrier, with a clamping force of 80 kN per station.
  5. Water heating units circulate hot water through the moulds, heating them to 55–75°C for proper foam formation.
  6. After one full conveyor circuit, the carrier reaches the operator area, the mould opens and the cured PUR foam component is removed. The cycle repeats.

Thus, the system is a multi-station, continuous reaction injection moulding line where chemical components are injected into moulds, subjected to clamping and heating, and solidify into finished plastic foam parts.

The Authority examined two core questions:

1.