2026-VIL-15-AAR

SGST Advance Ruling Authority

GST – Andhra Pradesh AAR - Classification of spent bleaching earth and applicable GST rate - Manufacture of edible oils, including extraction and refining of rice bran oil – Classification and applicable GST rates for 'spent earth' generated during the edible oil refining process – HELD - The spent earth is a mineral-based, chemically activated, and supplied as an exhausted adsorbent, which directly aligns with the description under HSN 3802 90 19 - In accordance with the General Rules for Interpretation, the classification of goods for GST and Customs purposes must be based on the nature and condition of the goods at the time of supply. HSN 2508, which relates to clays, kaolin, bentonite, and other earths, covers raw or processed non-activated clays used for industrial purposes. However, since the spent bleaching earth has been chemically or thermally activated and used as an adsorbent, classification under HSN 2508 would ignore the functional and chemical characteristics of the product and is therefore not legally or technically appropriate - On the other hand, HSN 3802 under Chapter 38 specifically covers activated carbon, activated natural mineral products, and animal black, including spent animal black. Subheading 3802 90 19—"activated natural mineral products – Other"—is a residual category that includes activated natural mineral products even when spent or exhausted - The correct HSN code for the 'spent earth' is 3802 90 19 - "activated natural mineral products: other", with applicable GST rate of 18% - Ordered accordingly

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