The Bangalore Bench of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) has held that “Automatic Soap Dispenser” imported by Xiaomi Technology India Pvt. Ltd. cannot be classified as a toiletry spray under Customs Tariff Item (CTI) 9616 10 20, observing that the product disperses liquid soap foam and does not perform the function of spraying.
The bench Justice Dilip Gupta (President) and R. Bhagya Devi (Technical Member) has observed that Chapter Heading 9616 relates to sprays such as scent sprays and similar toiletry sprays. The tariff itself separately uses the expressions “dispersing” and “spraying,” thereby indicating that the two functions are distinct. According to the Tribunal, a product which disperses liquid soap foam cannot automatically be treated as a spray appliance merely because it is used for toiletry purposes.
The dispute arose after the Deputy Commissioner of Customs, through an order dated 17.01.2024, reassessed three Bills of Entry and classified the imported “Automatic Soap Dispenser” under CTI 9616 10 20 instead of CTI 8424 89 90 as declared by the importer. The Commissioner (Appeals) subsequently upheld the reassessment order, following which the matter reached the Tribunal.
Before the Tribunal, the appellant explained the functioning and technical specifications of the imported product. It was submitted that the product is a sensor-based automatic soap dispenser designed for touchless dispensing of liquid soap in foam form. The device contains an in-built infrared proximity sensor which detects a user’s hand and dispenses foam within approximately 0.25 seconds. The dispenser operates through a diaphragm pump and motor mechanism which mixes air and liquid soap in a specified ratio to generate foam.
Counsel for the appellant argued that the product squarely falls under Chapter Heading 8424 dealing with mechanical appliances for dispersing liquids. It was contended that the imported goods merely disperse soap foam and do not spray liquids, which is the essential characteristic contemplated under Heading 9616 relating to sprays and toiletry sprays.
On the other hand, the Department contended that the imported item was a toiletry product more appropriately classifiable under Chapter Heading 9616 and therefore excluded from Chapter Heading 8424.
After considering the rival submissions, the Tribunal examined the nature and functioning of the imported product. The Bench observed that Chapter Heading 8424 specifically covers mechanical appliances for dispersing liquids and noted that the automatic soap dispenser admittedly disperses liquid soap in foam form through a mechanical process.
The Bench also referred to the Harmonized System of Nomenclature (HSN) explanatory notes to Chapter Heading 9616, which specifically exclude appliances covered under Chapter 8424 dealing with dispersing or spraying mechanisms.
Holding that the imported “Automatic Soap Dispenser” is appropriately classifiable under CTI 8424 89 90, the Tribunal concluded that the Commissioner (Appeals) had committed an error in classifying the goods under CTI 9616 10 20. Consequently, the appellate order dated 26.09.2024 was set aside and the appeal was allowed in favour of the importer.
Case Details
Case Title: M/s. Xiaomi Technology India Private Limited Versus Commissioner of Customs
Citation: JURISHOUR-1167-HC-2026(Ker)
Case No.: Customs Appeal No. 20155 of 2025
Date: 05.05.2026
Counsel For Appellant: Purvi Asati with Ms. Ashwini Nag, Advocates
Counsel For Respondent: M. Sreekanth, Assistant Commissioner (AR)
