The Customs Authority for Advance Rulings (CAAR), Mumbai has held that Laser Engraving Machines are not covered by Anti-Dumping Duty (ADD) imposed under Notification No. 15/2023-Customs (ADD) dated December 22, 2023, as they are distinct from industrial laser machines used for cutting, marking, or welding.
The applicant sought an advance ruling on whether imports of Laser Engraving Machines classified under Customs Tariff Heading (CTH) 84561100 would attract anti-dumping duty under Notification No. 15/2023-Customs (ADD), which imposes ADD on industrial laser machines used for cutting, marking or welding operations originating from China.
According to the applicant, its products consist of compact laser engraving machines intended for artistic, decorative, hobby, educational, jewellery, signage, and small commercial engraving applications rather than heavy industrial manufacturing.
Buy Now: Customs Duty Judgements E-Compilation – May 2026
The importer argued that the Directorate General of Trade Remedies (DGTR), while conducting the anti-dumping investigation, had consciously excluded laser engraving machines from the scope of the Product Under Consideration (PUC).
The applicant relied extensively on the DGTR’s Final Findings issued on September 27, 2023, pointing out that the domestic industry itself had not included laser engraving machines, laser bending machines, laser drilling machines, or laser cleaning machines within the scope of the investigation.
It further contended that the notification applies only to industrial laser machines used for cutting, marking or welding. DIY and desktop laser engraving machines are compact, portable systems designed for hobby, educational, artistic and personalization purposes. Such machines are commercially different from customer-made industrial production systems. They are neither manufactured nor marketed as industrial capital goods.
The applicant also emphasized that these engraving machines are sold based on engraving area, portability, wattage, software compatibility, and user convenience rather than industrial bed sizes or heavy-duty manufacturing specifications.
The applicant also cited the Supreme Court’s decision in Chief Commissioner of CGST v. Safari Retreats Pvt. Ltd. (2024) on interpretation of taxing statutes.
It argued that taxation statutes must be interpreted strictly, nothing can be added by implication, and where two interpretations are possible, the one favourable to the taxpayer should ordinarily prevail.
During the proceedings, CAAR examined detailed catalogues and specifications of various imported models including LaserPecker LP1 Pro, LaserPecker LP2, LaserPecker LP3, LaserPecker LP4, and LaserPecker LP5
The Authority noted that these were portable or desktop engraving machines intended primarily for engraving applications involving wood, acrylic, leather, jewellery, signage and other light materials rather than industrial production environments.
The Authority first observed that laser engraving machines are correctly classifiable under CTH 84561100, which broadly covers machine tools operated by laser for removal of material.
However, it clarified that classification under the Customs Tariff and liability to anti-dumping duty are two distinct legal issues.
While tariff classification depends on the technical characteristics of the goods, applicability of anti-dumping duty depends upon whether the imported goods fall within the Product Under Consideration (PUC) defined by the DGTR and the relevant notification.
CAAR noted that Notification No. 15/2023 specifically covers: “Industrial Laser Machines, in fully assembled, SKD or CKD form, used for cutting, marking or welding operations.”
The Authority found that the applicant’s imported products were compact engraving systems intended primarily for artistic, decorative and hobby applications, and not industrial production laser systems.
A significant factor influencing the ruling was the DGTR’s own Final Findings, which repeatedly stated that laser engraving machines were not included within the Product Under Consideration; industrial laser machines under investigation were customer-made industrial capital goods developed for specific industrial end-use requirements; and machines used for purposes other than cutting, marking or welding were excluded from the investigation.
The Authority held that these findings clearly distinguished laser engraving machines from industrial laser systems covered by the anti-dumping notification.
Accordingly, CAAR ruled that Laser Engraving Machines imported by M/s Nikoarc Industries Pvt. Ltd. are not covered by Notification No. 15/2023-Customs (ADD).
The AAR concluded that although both industrial laser machines and laser engraving machines may fall under the same customs tariff heading, the latter do not satisfy the technical, commercial and functional characteristics of the industrial laser machines covered under the anti-dumping notification and are therefore not liable to Anti-Dumping Duty.
Membership Required to Access Case Details & Order Copy
To view the complete Case Details and Download Order Copy, you must have an active membership. Please subscribe to continue.
