2026-VIL-166-AAR
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SGST Advance Ruling Authority

GST – Kerala AAR - Classification of "Nata De Coco (Coconut Jelly)" and applicable rate of tax - Applicant manufactured Nata De Coco from coconut water and coconut milk - Whether the product is classifiable under HSN Code 20079990 and the applicable rate of GST thereon - HELD - Heading 2007 covers jams, fruit jellies, marmalades, fruit or nut puree and fruit or nut pastes obtained by cooking, being preparations where fruit juice or pulp is boiled or concentrated with sugar until it sets on cooling, the fruit or nut remaining the essential ingredient giving the product its essential character - Nata De Coco is not obtained by boiling or concentrating coconut juice or pulp so as to form a jelly on cooling, but results from microbial fermentation of coconut water and milk used only as a substrate, followed by further processing, and is a distinct fermented edible preparation not marketed or consumed as a jam, marmalade, puree or paste - Product accordingly does not satisfy the description under Heading 2007 - Heading 2008, covering fruit, nuts and other edible parts of plants otherwise prepared or preserved while retaining their essential plant character, is also inapplicable since coconut water and milk are used only as substrate for fermentation and the finished product does not retain the essential character of coconut as such - No other specific heading being applicable, the product falls under the residual Heading 2106 covering food preparations not elsewhere specified or included, and more specifically under Tariff Item 21069099 - Among the entries under Heading 2106, the product does not meet the specific descriptions under other entries, and would fall either under the entry for ready-to-eat packaged food, if supplied as such, or the residual entry for goods not specified elsewhere, both attracting the same rate for the relevant period - Product held classifiable under Heading 2106, Tariff Item 21069099, and not under Heading 2007 – GST is payable at 18% for the period from 01.07.2017 to 21.09.2025, and at 5% with effect from 22.09.2025 as Nata De Coco is appropriately classifiable under Sl. No. 145 of Schedule I to Notification No. 9/2025-Central Tax (Rate), dated 17.09.2025 – Ordered accordingly
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