2025(05)LCX0522(AAR)

Aptive Components India Private Limited

decided on 07-05-2025

DIN-20250574OR0000671485

CUSTOMS AUTHORITY FOR ADVANCE RULINGS
O/o COMMISSIONER OF CUSTOMS
NEW CUSTOM HOUSE, NEAR IGI AIRPORT, NEW DELHI-110037
[Email:cus-advrulings.del@.gov.in]

Shailesh Kumar (Customs Authority for Advance Rulings, New Delhi)

F. No. VIII/CAAR/DeIhi/Aptiv(Meenambakkam)/219/2024

The day of 07, May, 2025

Ruling No. CAAR/Del/Aptiv/27/2025/164 to 170/07/05/2025

In application No. 190/2024 dated 22.01.2025

Ruling

M/s Aptiv Component India Private Limited ('Applicant'), a company having its registered corporate office located at Plot No, 7, Industrial Area, Dharuhera-122106, Dist. Rewari, Haryana, India, and is holding IEC number 0595006019. The Applicant is engaged in the business of automotive technology solutions, providing comprehensive vehicle architecture encompassing software, hardware, and electrical/electronic systems.

1.1. The Applicant has approached the Customs Advance Rulings Authority for determining the classification of following models of Choke coils, which are being imported by the Applicant since First Quarter of 2022-23 from China for use in electronic circuits to block or "choke" high-frequency alternating currents (AC) while allowing lower-frequency or direct currents (DC) to pass through. These seven specific products can be categorized as the choke, which common functionality and features relevant for determining their appropriate classification:

1.2 The Applicant submitted that even though detailed description and product numbers are different, all the seven goods answer to the product name of "choke coils". All the common choke coils are differentiated solely by their impedance, measured in ohms. Therefore, a single application for pronouncing ruling on their appropriate classification has been submitted, placing reliance on the ruling issued by Hon'ble CAAR authority of New Delhi, in the matter of Amazon Wholesale India Pvt. Ltd having Ruling No. CAAR/Del/Amazon/17/2021, dated 20-7-2021 [2021 (378) E.L.T. 700 (A.A.R. - Cus. - Del.)], wherein 11 products under a single application for a family of Echo devices having common functionality and features, were covered.

    Product usage, functions and other technical capabilities

1.3 The product under consideration is a choke coil, or simply referred to as "choke," is an inductor used in electronic circuits to block or "choke" high-frequency alternating currents (AC) while allowing lower-frequency or direct currents (DC) to pass through. It consists of a coil of wire, often coiled around a magnetic core. Choke coils are used in power supplies and Radio Frequency circuits to filter out unwanted noise, stabilize current, and reduce electromagnetic interference (EMI). The image of the product under consideration is reproduced below:

Technical Details of product

1.4 The product under consideration is essentially a type of inductor specifically designed to store energy in a magnetic field when electric current passes through it. A choke coil possesses the properties of inductors in following ways:

•  Choke coils operate on the principle of inductance, which is the property of an electric conductor to oppose changes in current.
   

• Choke coils exhibit inductive reactance, which increases with frequency. This means they resist the flow of alternating current (AC) while allowing direct current (DC) to pass through, making them useful for filtering and smoothing out signals.
   

• Choke coils store energy in their magnetic field, which can be released back into the circuit when the current decreases. This ability to store and release energy is a fundamental characteristic of inductors.
   

• As highlighted above in the images, choke is a device that typically consists of an insulated wire coiled into a coil, often around a magnetic core. Its operation is based on the principle of self-induction, an electrical phenomenon where a changing current induces a voltage within the coil itself.

Application of product under consideration;


1.5 The product under consideration is designed to use by the Applicant in manufacturing of electronics items to be used in automobiles having various applications such as noise filtering/ suppression for automotive CAN-BUS (Controller Area Network Bus)/ CAN-FD (Controller Area Network with Flexible Data Rate)/ Flex Ray Systems and signal line, automotive A2B (Audiobus) system & C2B (Car camera bus) systems, Multimedia systems and Ethernet etc.

Chain of events leading to the present Application;

1.6 The Applicant is importing the product under consideration from first quarter of FY 2022-23 self-classifying the same under HSN 8504 50 90. It is pertinent to highlight that the HSN currently adopted by the Applicant is align at 6-digit level with the proposed entry (i.e., 8504 50 10). There exists an ambiguity regarding the appropriate classification of the product under consideration at last two digit. As per the applicant, several industry participants are adopting 8504 50 10 for classification of choke coil as it specifically covers choke coil. These competing classifications, resulting in absence of certainty, are as follows:

1.7 In addition to the above, the rate of applicable custom duty remains the same. Hence, the issue pertaining to classification is revenue neutral. In view of the above facts, the applicant has approached this office to seek clarity on appropriate classification of the choke choil used by the Applicant in filtering unwanted noise from power lines and signals.

Statement containing the Applicant's interpretation of law and facts in respect of the aforesaid question(s)

A, Classification of the product under consideration under CTH 8504.

1.8 The heading of Chapter 85 covers electrical transformers, static converters and inductors. For ease of reference, the relevant extract of the Schedule 1 to the Customs Tariff Act, 1975 has been provided below:

1.9 In terms of Explanatory Notes, 2022 Edition as issued by the World Customs Organization (hereinafter referred to as 'WCO Explanatory Notes') for Tariff Heading 8504, this heading covers inductors which are essentially consist of a single coil of wire which, inserted in an AC circuit, limits or prevents by its self-induction the flow of the AC. These inductors may vary from small chokes used in wireless circuits, instruments, etc., to large coils often mounted in concrete, used in power circuits for limiting the flow of current in the event of a short circuit. The relevant excerpt from the explanatory notes is reproduced below:

"III- INDUCTORS
These consist essentially of a single coil of wire which, inserted in an AC circuit, limits or prevents by its self-induction the flow of the AC. They vary from small chokes used in wireless circuits, instruments, etc., to large coils often mounted in concrete, used in power circuits (e.g., for limiting the flow of current in the event of a short circuit). "

1.10 A perusal of the above explanatory notes suggests that CTSH 8504.50 covers different type of inductors that are used to limit or prevent the flow of the AC. These sub- heading covers a broad range of chokes that is used in wireless circuits, power circuits etc. These chokes may vary in sizes i.e., from small chokes used in wireless circuits, instruments, etc., to large coils often mounted in concrete, used in power circuits for limiting the flow of current in the event of a short circuit. The Applicant uses the product under consideration for noise filtering/suppression and for limiting the flow of AC current in Flex Ray Systems, A2B & C2B systems etc.

1.11 As enumerated in the above para, the product in question primary function is to limit or prevent the flow of the AC current. The chokes imported by the Applicant are used for noise filtration/suppression which is achieved by restricting the flow of AC current in Flex Ray Systems, A2B & C2B systems etc. Therefore, it is submitted that imported chokes are directly covered under CTH 8504 which provides for inductors - choke coils.

1.12 The Applicant submitted that product under consideration would merit classification under HSN 8504 50 10. As such, this entry specifically covers chokes coils of varying sizes. Hence the appropriate classification for the subject goods should be under tariff entry 8504 50 10 (i.e., Choke coil).

1.13 This position is also supported by the decision of the Hon'ble Supreme Court in the case of Collector of Customs Vs. Business Forms Ltd. - 2002 (142) E.L.T. 18 (S.C.), specifically referring to paragraph 2 of the said judgment, wherein it was established that the HSN Explanatory Notes carry not only persuasive weight but also deserve greater consideration in the process of classifying goods under the Customs Tariff.

1.14 Further, the applicant placed reliance on General Rules for the interpretation (GRI)-l, which states that "Classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes." By application of GRI1, the product in question is directly covered under CTH 8504 by virtue of the chapter heading & explanatory notes.

1.15 Therefore, the applicant is of the view that Choke coils is classifiable under CTH 8504 50 10 as it specifically covers choke coils (chokes) which provides the most specific description vis-a¬vis CTH 8504 5090 which covers other type of inductors providing a more general description.

1.16 Furthermore, reference can also be drawn to GR1-6 which states that "The classification of goods in the subheadings shall be determined according to the terms of those subheadings basis the understanding that only subheadings at the same level are comparable". The relevant rule is extracted below for ease of understanding:

"Rule 6
For legal purposes, the classification of goods in the subheadings of a heading shall be determined according to the terms of those subheadings and any related subheading notes and, mutatis mutandis, to the above rules, on the understanding that only subheadings at the same level are comparable. For the purposes of this rule, the relative section, chapter and subchapter notes also apply, unless the context otherwise requires.

1.17 CTH 8504 is divided into six 1 -dash sub-headings. The fifth one-dash subheading (i.e., 8504 50) covers inductors that very from small chokes to large choke coil. This fifth one-dash subheading is further divided into two three-dash subheadings which covers Choke coil (Choke) and other inductors respectively. It is pertinent to note here that GIR 6 provides that classification of goods is based on relevant terms of the subheadings emphasizing that only subheadings at the same level are comparable.

1.18 Therefore, by applying the rationale of GIR 6, we are of the view that Choke coil is classifiable under CTH 8504 50 10 as the relevant terms of three-dash subheading specifically covers Choke coil (Choke) vis-a-vis the other entry that covers other inductors.

1.19 Further, the applicant submitted that the declaration provided by suppliers (namely Sunlord Electronics Co., Ltd and Cyntec Co., Ltd) who were engaged in the development, manufacturer, and sales of electronic components such as chokes, ferrite beads, chips etc. These declaration from two of the suppliers further corroborated our position that the product in question functions as an inductor, primarily used for noise filtration/suppression or for limiting the flow of current and therefore, choke coils are appropriately classifiable under tariff entry 8504 50 10.
Copy of declarations from suppliers (namely Sunlord Electronics Co., Ltd and Cyntec Co., Ltd)

1.20 The applicant asserted that provided declaration from the supplier facilitates clear understanding of the functionality of product in question as an inductor which enables it to be correctly classifiable under tariff entry 8504. 50.10. Hence, the Applicant humbly submits that the product under consideration is classifiable under CTH 8504 50 10 emphasizing the following:

• The product under consideration is an inductor that is used for noise filtration/suppression or for limiting the flow of current.
   

• There is a specific entry for product under consideration under CTH 8504 50 10 that covers Choke coil (Choke)
   

• Further, applying the rationale of GIR 3(a) and 6, the product under consideration is correctly classifiable under CTH 8504 50 10.

1.21 The applicant further submitted that the questions raised by it in their application are not pending before any officer of Customs, Appellate Tribunal or any Court of Law and they have not been issued any summons mandating it to provide any kind of information with respect to import of the subject goods. However, they clarified that the issuance of such summons by any officer of Customs is not equivalent to the questions being pending before any officer of Customs, Appellate Tribunal or any Court of Law.

1.22 In its regard, the applicant placed reliance on M/s Spraytec India Ltd versus Directorate of Revenue Intelligence (2023) 4 Centax 211 (Del.) wherein the Hon'ble Delhi High Court adjudicated on whether the classification concluded by Hon'ble Customs Authority of Advance Ruling (CAAR) was erroneous or not as the goods imported under the said CTHs were at the time detained at the port of import. It was held that the Order passed by Hon'ble CAAR. was valid as only summons had been issued and no pre-consultation notice or show cause notice had been issued by DRI or any other Authority. Hence, it would be erroneous to hold that the question of classification was pending before any Custom officer, Appellate Tribunal, or any Court.
For ease of reference, the relevant extract of the case has been provided below:

A. "The proviso to Sub-Section (2) of 28-1 of the Customs Act proscribes the CAAR from allowing any application filed for advance ruling, where question raised in the application is pending in the applicant's case before "any officer of customs, the Appellate Tribunal or any Court" or if the said question has already been decided by the Appellate Tribunal or any Court. In the present case, DRI had not issued any pre-consultation notice or show cause notice which would indicate that the question regarding classification of any goods was pending before DRI. Thus, even if it is accepted that an officer of DRI is an officer of Customs, it cannot be accepted that the question raised by the respondent in its application under section 28H of the Customs Act was pending 'in the applicant's case' before DRI. In order for a question to be considered as pending before any officer of customs, it would be necessary for the question to be raised in any notice enabling the assessee to respond to the said issue. It is only after this stage that it would be necessary for the officer of customs to render its decision on the question. Merely because an officer of customs contemplates that a question may arise, does not mean that the question is pending consideration. For a question to be stated to be pending, the concerned officer must formally set forth the same for the assessee to contest the same. Any preliminary exercise done by an officer of customs, to consider whether any question for consideration arises, would not preclude the CAAR from giving its advance ruling on that question. The possibility that a question would arise for consideration of a customs officer, appellate tribunal or court, is not a ground contemplated under clause (a) of the proviso to Section 28-1(2) of the Customs Act. Clearly, a distinction must be made between that question pending consideration and a possibility of a question arising consideration. "

1.23 Additionally, the applicant placed reliance on an advance ruling issued to H.Q. Lamps Manufacturing Co. Ltd., wherein CAAR, New Delhi opines that an investigation is considered pending before an officer when a show cause notice or pre-consultation notice has been issued. For ease of reference, the relevant extract of the case is provided below:

"13.6 On the basis of the careful examination of the relevant provisions of the Customs Act, Rules and CAAR Regulations, 2021, 1 am on the considered view that an application may be considered "pending" before any officer of customs only if it is pending before an officer in formal manner before an officer who is competent to answer the said question in terms of specific powers vested with the officer under the Customs Act, 1962. An illustrative list of such situations would include cases wherein a Show Cause Notice has been issued; bill of entry has been provisionally assessed under section 18 of the Act ibid; the matter is pending before the Special Valuation Branch of the Customs Commissioner for the purpose of valuation of the goods in question; or the proper officer has held the pre-notice consultation with the applicant in terms of the proviso of sub-section (a) of Section 28(1) of the Customs Act, 1962. Therefore, in cases, such as the extant case, wherein an officer of customs is engaged in an investigation that may result in formulation of a question that would be posed before another competent officer would not qualify as "pending before an officer

13.7 In view of the above, I reject the contention of the Principal Commissioner of Customs (Preventive), New Delhi and allow the application for advance ruling in terms of Section 28-1 (2) of the Customs Act"

1.24 Hence, in the present context, the applicant submitted that the questions raised by it in the present application are not pending before any officer of Customs, Appellate Tribunal or any Court of Law.

1.25 In light of the facts, relevant legal provisions and the applicant's submissions made in the above paragraphs, our humble prayer before your good self is as follows:

• Confirm that the product under consideration is classifiable under tariff entry 8504 50 10 as Choke coil (Choke); and
   

• Allow us to present our case in a personal hearing before your good-self prior to issuance of any Order.

Comments of the Port Commissionerate

2. As per the provision of CAAR Regulation, 2021, the complete application of the applicant was provided to the concerned Customs Commissionerate i.e. Chennai-VII (Air Cargo) Commissionerate, and requested to furnish the requisite comments in the instant matter. The port authority vide its letter dated 17.04.2025 furnished its comments as follows :-

2.1 i. As the applicant is an IEC holder, they are eligible for filing the application for advance ruling in terms of section 28 E (c)(i) of the Customs Act, 1962.

ii. As no records from this Commissionerate have been specifically called for in respect of the question raised in the application, proviso 1 to section 28-1 (2) of the Customs Act, 1962 is not applicable in this case.

iii. The claim of the applicant about nature of the activity noticed to be importation of the goods under reference, which is ongoing.

iv. Regarding merits of the issue, the comments by the concerned Customs Commissionerate, Chennai is as under:

v. Regarding whether the question on which advance ruling has been sought is already pending in the applicant case before any officer of Customs, the appellate tribunal or any court, it is submitted that based on the data available in this Commissionerate, it is not pending before any officer of Customs, the appellate tribunal or any court nor decided already by the Appellate Tribunal or any court.

Comments on the merits of the question raised, by port aurhority

2.2. About the product

2.2.1 As described by the applicant:

• The product under consideration has been stated as Choke coils consisting a total of 7 product numbers, consisting of Murata, TDK and Sunlord brands, for use in electronic circuits to block or choke high-frequency alternating currents (AC), while allowing low frequency direct currents (DC) to pass through.
   

• The images of the items are provided as under:
   

• "Choke coil" or "Choke" is an Inductor, consists of a coil of wire, often coiled around magnetic core. It is specifically designed to store energy in a magnetic field when electrical current passes through it.
   

• Choke coils are used in power supplies and radio frequency circuits to filter out unwanted noise, stabilize current and reduce electromagnetic interference.
   

• Choke coils operate on the principle of inductance, which is property of an electrical conductor to oppose changes in current.
   

• Choke coils exhibit inductive reactance, which increases with frequency. This means they resist the flow of AC while allowing DC to pass through, making them useful for filtering and smoothing out signals.
   

• Choke coils store energy in their magnetic field, which can be released back into the circuit when the current decreases. This ability to store and release energy is a fundamental characteristics of inductors.
   

• Its operation is based on the principal of self-induction, an electrical phenomenon where a changing current induces a voltage within the coil itself.
   

• These choke coils are designed to use by the Applicant in manufacturing of electronics items to be used in automobiles having various applications such as noise filtering / suppression for automotive CAN-BUS, CAN-FD, Flex ray systems, single line automotive A2B systems, C2B systems, Multimedia systems, Ethernet etc.

2.2.2 As available in the website of the supplier:

• Based on the models provided, it is understood from the websites of murata, tdk and SUNLORD that the choke coils under reference are categorised under EMC products and further categorised as common mode choke coils.
   

• Common mode choke coils are also a type of noise filter, but rather than using differences in frequency, they separate noise from signals by differences in conduction mode.
   

• In the electrical circuit of a circuit board,, the current flowing out from a certain part reaches another circuit through the load, and returns to the origin via a different route on the circuit board. This type of flow is called differential mode (or normal mode). Another conduction route also exists, though not as a clear-cut wire. A tiny amount of stray capacitance is generated between the wires on the circuit board and the reference ground surface, creating a conduction route where the capacitance flows commonly through all wires on the circuit board and returns in the opposite direction along the reference ground surface. This route is called common mode.
   

• Common mode choke coils are made up of two conducting wires wrapped around a single core (a ferrite core when used in high-frequency applications). They therefore have four terminals. The wires are wrapped around the core in opposite directions. When common mode currents flow through coils with this type of structure, flux is generated by the electromagnetic induction phenomenon that occurs in each coil. However, as the direction of the generated flux is the same, both fluxes become stronger to increase their action as inductors. Conversely, differential mode currents flowing through the coil generate flux in opposing directions that cancel each other out. As a result, it no longer acts as an inductor against the differential mode current. Common mode choke coils are therefore filters that only act as inductors for common modes, and not against differential modes.
   

• Common mode choke coils (CMCC) are filters that reduce common mode noise that is problematic in differential transmission lines (non-automotive use: USB, HDMI, Mipi, etc.; automotive use: CAN, CAN-FD, lOOBase-Tl, lOOOBase-Tl, SerDes, APBM, etc.), power lines, and audio lines. They are ideal for suppressing common mode noise with frequencies ranging from several megahertz to several hundred megahertz with no adverse effect on the signals (upper cut-off Products can also be searched by series or application, frequency).
   

• Common mode choke coils are designed so that the magnetic flux produced in the two coils by the differential mode current cancel each other out as much as possible. However, some common mode choke coils are designed so that not all of the magnetic flux cancels each other out, and some magnetic flux leaks.
   

• Common mode choke coils have two advantages. (1) Even when the frequencies of signals and noise overlap, their different conduction modes enable suppression of only noise.; (2) Performance does not decrease even with a large differential mode current, as the core does not become saturated.
   

• The most important feature of common mode choke coils is their ability to distinguish between noise and signals even of the same frequency. Recently, more and more electronic devices are starting to use high-speed differential transmission as their method for transmitting signals. USB, SATA, and HDMI are typical examples of high-speed differential transmission.

2.2.3 Comments about the product:

It has been observed from both the submissions of the applicant as well as from the literature made available by the supplier / manufacturer in their websites that the choke coils under consideration are common mode choke coils, which function as the inductors. These chokes are a type of noise filters, but rather than using differences in frequency, they separate noise from signals by differences in conduction mode.

2.4 About the classification:

2.4.1 As observed by the applicant: At present they are self-classifying these Choke coils under appropriate CTSH of 8504 50 at six-digit level and under CTI 8504 5090 as other inductors at eight-digit level. However, they understood that several industry participants are classifying it under CTI 8504 5010, which is a specific entry for choke coils. The ambiguity in this case is only at the level of last two digits of the entries. However, the rate of duty among these two entries remain same. The importer has claimed classification under 85045010.

2.4.2 Comments on the classification:

2.2.1 The item Choke Coil is specifically reflected under CTI 8504 5010, which is pertaining to CTSH 8504 50 of "Other Inductors" under the CTH 8504 pertaining to "Electrical transformers, static converters (for example, rectifiers) and inductors". HSN Explanatory Notes to CTH 8504 is extracted as under:

(III) INDUCTORS

These consist essentially of a single coil of wire which, inserted in an AC circuit, limits or prevents by its self-induction the flow of the AC. They vary from small chokes used in wireless circuits, instruments, etc., to large coils often mounted in concrete, used in power circuits (e.g., for limiting the flow of current in the event of a short circuit). Inductors or inductances obtained in the form of individual components by a printing process remain classifiable in this heading.
Deflection coils for cathode-ray tubes are classified in heading 85.40.

2.4.3 From the above, it is noticed that different types of inductors are included under CTH 8504. In view of the above, it is noticed that even though the Inductors under consideration are mainly used for the purpose of suppression of noise in circuits by acting as a high-frequency impedance, such activity is being achieved by the self-induction. Therefore, in view of the HSN Explanatory Notes to CTH 8504, it appears that the functionality of the common mode choke coils under consideration is included in the terms of heading 8504.

2.4.4 From the Customs Tariff Act, 1975, the grouping of articles under CTH 8504 is as under:

2.4.5 From the above, it appears the choke coils under consideration, are specifically mentioned under CTI 8504 5010. Thus, in terms of Rule 1 of the General Rules for Interpretation of Customs Tariff or HSN (GIR), they appear rightly classifiable under CTI 8504 5010 instead of CTI 8504 5090, which is pertaining to residual entry of others under CTSH 8504 50 inductors - Other inductors.

2.5 In view of the above, the item under consideration viz Choke Coils appear rightly classifiable under CTI 8504 5010 as claimed by the applicant.

Personal Hearing

3. The personal hearing in the matter was conducted on 01.05.2025 wherein the port authority i.e. Chennai-VII (Air Cargo) Commissionerate and the authorized representative of the applicant attended the same. During the personal hearing, the authorized representative reaffirmed the points that had already been presented in the applicant's initial submission. Likewise, the port authority reiterated the arguments and details previously outlined in their formal response.


Analysis and Conclusion

4. After finding that the application is valid in terms of the provisions of the Customs Act, 1962 and the CAAR Regulations, 2021, having gone through CAAR-1 application, reply from jurisdictional Commissionerate, oral submissions made during the hearing and the legal framework governing the classification of proposed imports in the form of relevant Chapter notes, Section notes and HSN Explanatory Notes to the respective Chapter headings. I proceed to deliberate upon the issue on the basis of information available on record.
4.1 The issue involved is whether the impugned goods, namely, Choke Coils can merit classification under tariff item 8504 50 10 or 8504 50 90 of the Customs Tariff Act, 1975. In order to decide the same, it is imperative to examine both competing tariff items which covers following:-

4.2 The relevant explanatory note to tariff heading 8504 are reproduced below:-

(I) ELECTRICAL TRANSFORMERS

(II) ELECTRICAL STATIC CONVERTERS

(III) INDUCTORS

These consist essentially of a single coil of wire which, inserted in an AC circuit, limits or prevents by its self-induction the flow of the AC. They vary from small chokes used in wireless circuits, instruments, etc., to large coils often mounted in concrete, used in power circuits (e.g.. for limiting the flow of current in the event of a short circuit). Inductors or inductances obtained in the form of individual components by a printing process remain classifiable in this heading. Deflection coils for cathode-ray tubes are classified in heading 85.40."

4.3 Upon a perusal of Tariff Heading 8504 of the First Schedule to the Customs Tariff Act, 1975, it is observed that the heading covers "Electrical Transformers, Static Converters (for example, Rectifiers) and Inductors." Sub-heading 8504 50 pertains to "Other Inductors," wherein Tariff Item 8504 50 10 specifically covers "Choke Coils (Chokes)," and Tariff Item 8504 50 90 covers "Other Inductors."

4.4 Upon examination of the Harmonized System Explanatory Notes to tariff heading 8504, it is noted that inductors are essentially composed of a single coil of wire. When inserted into an AC circuit, these inductors utilize the principle of self-induction to limit or prevent the flow of alternating current. Their application ranges from small chokes used in devices such as wireless circuits and measuring instruments, to large coils—often embedded in concrete—used in power circuits to control current, particularly during short circuits. Additionally, inductors or inductances produced as discrete components through printing processes also fall under this classification. However, it is important to note that deflection coils for cathode-ray tubes are specifically classified under heading 8540.
 

4.5 In the present case, the applicant has submitted detailed technical specifications, catalogues, and supporting documents relating to the product under consideration, namely "choke coil." On examination, it is found that the said product is a type of inductor used primarily in electronic circuits to block high-frequency AC while allowing DC or low-frequency signals to pass. The construction comprises an insulated wire wound around a magnetic core, and the choke coil is deployed in power supplies and radio-frequency circuits for purposes such as noise filtering, current stabilization, and EMI suppression. The product functions on the principle of inductance, opposing changes in current and storing energy in a magnetic field to be released back into the circuit as required. The mechanism is based on self-induction. Additionally, it is noted that these choke coils are used in the manufacturing of automotive electronic components, particularly in applications involving CAN-BUS, CAN-FD, FlexRay, A2B, C2B systems, multimedia systems, and automotive Ethernet.

4.6 From the evidence furnished, it is observed that the subject goods are common mode choke coils, which function as inductors. These are specialized noise filters that attenuate unwanted signals based on differences in conduction mode rather than frequency. It is further noted that the applicant is classifying the subject goods under Tariff Item 8504 50 90 as "Other Inductors."

4.7 The classification of goods under the First Schedule to the Customs Tariff Act, 1975, is governed by the General Rules for the Interpretation of the Schedule (hereinafter referred to as "GRI"). As per Rule 1 of the GRI, classification shall be determined according to the terms of the headings and any relevant Section or Chapter Notes, with the titles of Sections, Chapters, and sub-Chapters being provided for ease of reference only. Rule 3(a) of the GRI provides that where goods are, prima facie, classifiable under two or more headings, the heading which provides the most specific description shall be preferred over headings that provide a more general description. The Rule 3(a) of the GRI is reproduced below:-

"3. When by application of Rule 2 (b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows :

(a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods or to part only of the items in a set put up for retail sale, those headings are to be regarded as equally specific in relation to those goods, even if one of them gives a more complete or precise description of the goods.

(b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3 (a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable.

(c) When goods cannot be classified by reference to 3 (a) or 3 (b), they shall be classified under the heading which occurs last in numerical order among those which equally merit consideration.'''

4.8 In the present case, it is evident that sub-heading 8504 50 includes two tariff items: (i) 8504 50 10, covering "Choke Coils"; and (ii) 8504 50 90, which is a residual entry for "Other Inductors." Based on the description, technical characteristics, and functional use of the product in question, it is clear that the same qualifies as "Choke Coils" specifically covered under Tariff Item 8504 50 10. It is a well-settled principle of classification under tariff act that where a specific entry is available for a particular product, classification under a residual or general entry is not permissible. In this regard, reliance is placed on the following judgments of the Hon'ble Supreme Court, which uphold the primacy of specific tariff entries over residual entries under the First Schedule to the Customs Tariff Act, 1975.

(i) In case of Commissioner Of Central Excise Versus Wockhardt Life Sciences Ltd.{2012 (277) E.L.T. 299 (S.C.)}, it was held that Classification of goods - Determination of - It cannot be under residuary entry in presence of specific entry, even if it requires product to be understood in technical sense - Residuary entry can be taken refuge of only in absence of specific entry.

(ii) In case of Western India Plywoods Ltd. Versus Collector of Customs, Cochin {2005 (188) E.L.T. 365 (S.C.)} it was held that Classification of goods - Application of residuary entry to be made with extreme caution, being attracted only when no other provision expressly or by necessary implication applies to goods in question.

(iii) In case of Commissioner of C. Ex., Bhubaneswar-I Versus Champdany Industries Ltd. (2009 (241) E.L.T. 481 (S.C.)}, it was held that Classification of goods - Specific v. residuary heading - Supreme Court decisions holding when specific heading exists, goods not classifiable under residuary heading and such principle hardened into a rule of law by reason of consistent view taken by the Court.

5.4 Further, it is also observed that the jurisdictional Commissionerate has concurred with classification of subject goods under Tariff Item 8504 50 10. Therefore, in view of the foregoing and in accordance with Rule 3(a) of the GRI, I am of the considered opinion that the product in question, namely "Choke Coils," is correctly classifiable under Tariff Item 8504 50 10.

6. I, rule accordingly.

(Shailesh Kumar)                        
Customs Authority for Advance Rulings, New Delhi

F. No. VIII/CAAR/Delhi/Aptiv (Meenambakkam)/219/2024                            Dated: 07.05.2025

This copy is certified to be true copy of the ruling and is sent to: -

1. M/s Aptiv Component India Private Limited, Plot No, 7, Industrial Area, Dharuhera-122106, Dist. Rewari, Haryana, India

2. The Principal Commissioner of Customs, Chennai- VII (Air Cargo), New Customs House, Air Cargo Complex, Meenambakkam, Chennai- 600016

3. The Customs Authority for Advance Rulings, Mumbai, New Custom House, Ballard Estate, Mumbai-400001.

4. The Chief Commissioner (AR), Customs Excise & Service Tax Appellate Tribunal (CESTAT), West Block-2, Wing-2, R.K. Puram, New Delhi-110066.

5. The Principal Chief Commissioner of Customs, Delhi Customs Zone, New Custom House, IGI Airport Complex, New Delhi-110037.

6. Guard file.

7. Webmaster.

(Harish Kumar)
Additional Commissioner & Secretary,
Customs Authority for Advance Rulings, New Delhi