The West Bengal Authority for Advance Ruling (WBAAR) has clarified the classification of polypropylene (PP) packing boxes under the Goods and Services Tax (GST) regime, ruling that such products are correctly classifiable under HSN 39231090, while their lids, caps, and covers fall under HSN 39235090. The Authority also confirmed that these products continue to attract 18% GST (9% CGST and 9% SGST for intra-state supplies, or 18% IGST for inter-state supplies). 

The advance ruling application was filed by a Kolkata-based manufacturer engaged in producing PP packing boxes made from plastic granules. The applicant sought an advance ruling solely to obtain certainty regarding the correct Harmonised System of Nomenclature (HSN) classification of its products, despite already charging GST at the applicable rate of 18%. 

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The applicant explained that it manufactures PP packing boxes using plastic granules through semi-automatic machinery installed at its manufacturing facility in Kolkata. The finished products are supplied either with or without corresponding lids, caps, and closures and are primarily used for packing goods. The company had been classifying the products under HSN Code 392390 but sought confirmation from the Authority regarding the precise tariff item applicable under the Customs Tariff Act. 

The application was admitted under Section 97 of the GST Act as it related to the classification of goods, and the jurisdictional revenue officer did not raise any objection to the maintainability of the application. 

During the proceedings, the Revenue did not make any substantive submissions on the merits of the issue. Consequently, the Authority proceeded to examine the applicant’s manufacturing process, product specifications, invoices, and supporting photographs to determine the appropriate tariff classification. 

The Authority analysed Chapter 39 of the Customs Tariff Act, 1975, which covers plastics and articles thereof. It noted that polypropylene is a polymer falling under tariff heading 3902 and that the manufacturing process described by the applicant squarely falls within the scope of Chapter 39, which encompasses articles produced by moulding or similar manufacturing processes. 

The bench further observed that tariff heading 3923 specifically covers “Articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and other closures, of plastics.” Since the applicant’s products are plastic boxes used for packing goods, they naturally fall within this heading. 

After analysing the tariff entries, the Authority held that PP packing boxes are in the nature of boxes, cases, crates, or similar plastic articles intended for packing goods. Since the products do not fit within any of the specifically enumerated tariff items under sub-heading 392310, they are appropriately classifiable under Tariff Item 39231090 (Other). 

The Authority also ruled that plastic lids, caps, and covers supplied with such packing boxes are separately classifiable under Tariff Item 39235090, which covers other plastic closures. 

The ruling further noted that sub-heading 3923 is covered under Serial No. 124 of Schedule II to Notification No. 01/2017-Central Tax (Rate), as amended by Notification No. 09/2025-Central Tax (Rate). Accordingly, all goods falling under this heading continue to attract GST at 18%, comprising 9% CGST and 9% SGST on intra-state supplies or 18% IGST on inter-state supplies.

The West Bengal Authority for Advance Ruling held that PP packing boxes manufactured by Jai Hind Plastic are classifiable under HSN 39231090. Lids, caps, and covers of such boxes are classifiable under HSN 39235090. The applicable GST rate remains 18% in terms of the relevant GST rate notification.

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