2026-VIL-1641-CESTAT-CHE-CU

CUSTOMS CESTAT Cases

Customs – Classification of Disposable Micro-cuvettes as Parts of Analytical Instrument – Appellant imported “STA Satellite Cuvettes”, sealed cartridge assemblies consisting of plastic body with small steel ball enclosed, designed exclusively for use with STAGO blood coagulation analysers - Appellant classified goods as spare parts under CTI 9027 9090. Customs Dept objected to this classification, contending that because the cuvettes are single-use disposable consumables, they must be classified as general plastic articles under CTI 3926 9099, which attract higher duty rates – Whether micro-cuvettes constitute identifiable parts or accessories of the STAGO coagulation analyser classifiable under Heading 9027 by virtue of Chapter 90 Note 2(b), or whether they are merely disposable consumable articles of plastic classifiable under residuary Heading 3926 – HELD – The micro-cuvettes are identifiable and functionally integrated parts and accessories suitable for use solely or principally with the STAGO coagulation analyser and are classifiable under CTI 9027 9090. The designation as single-use disposable does not by itself render an article a consumable or exclude it from being a part or accessory. A critical distinction exists between a disposable article (describing intended life or use-cycle) and a consumable article (describing one that is used up or loses identity in operation) - Where an article is specifically designed for, functionally integrated with, and necessary to the operation of a machine, it qualifies as a part or accessory irrespective of its single-use character. The micro-cuvettes participate actively in the coagulation analysis process; the plasma sample is contained within and the steel ball enclosed therein is subjected to magnetic control by the analyser to detect coagulation time. Chapter 90 Note 2(b) requires classification of parts and accessories, if suitable for use solely or principally with a particular machine, with that machine, without requiring permanent installation or incorporation - The article must be considered in its entirety as a specially designed cartridge with integrated steel ball intended for the particular analytical system. A specific tariff heading prevails over a general or residuary heading; material of construction by itself does not determine classification where the article has acquired a specific identity and function as a component of an analytical instrument - The micro-cuvettes are classifiable under CTI 9027 9090. Differential duty demand and interest are set aside. Penalty, confiscation and redemption fine do not arise - The impugned order is set aside and the appeal is allowed

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