Rice Husk Board Classified as Fibreboard Under Heading 4411: AAR Gujarat

The Gujarat Authority for Advance Ruling held that a rice husk and PVC composite board is fibreboard, not particle board, taxable at 12% before 22 Sep 2025 and 5% thereafter.

The Gujarat Authority for Advance Ruling has held that a board made of rice husk fibre bonded with about 27% PVC resin is fibreboard classifiable under heading 4411 of the First Schedule to the Customs Tariff Act, 1975, and not particle board under heading 4410. It attracts GST at 12% under Entry 92(c) of Schedule II to Notification No. 01/2017-Central Tax (Rate) before 22 Sep 2025, and at 5% under Entry 292(c) of Schedule I to Notification No. 09/2025-Central Tax (Rate) from that date. [In Re: Vegan Wood Private Limited, 2026-juristway.com-3269-AAR(Gujarat)-GST]

Sushma Vora, Member (SGST), and Vishal Malani, Member (CGST), gave the ruling on remand. An earlier ruling dated 21 Mar 2025 had found the application non-maintainable, citing an inadequate test report and missing invoices. The Appellate Authority for Advance Ruling set it aside on 25 Feb 2026 after the applicant produced invoices and fresh test reports.

At the remand hearing, the applicant called its product a ‘Natural Fibre Composite Board’ and framed a different question. The Bench held that the remanded application could not be altered, and treated the product as ‘Rice Husk Board’, the name used in the original application and on the sales invoices. Test reports from an accredited laboratory showed rice husk fibre of about 32%, PVC of about 27%, calcium carbonate of about 18% and additives for the rest.

Comparing the HSN Explanatory Notes, the Bench noted that particle board under heading 4410 is normally agglomerated with an organic binder that generally does not exceed 15% of the board’s weight. With PVC at over 27%, and with fibres first extracted from the husk instead of husk particles being bonded directly, the product moved out of heading 4410. Heading 4411 covers fibreboard of wood or other ligneous materials, whether or not bonded with resins, and rice husk is a ligneous material.

The Bench also held that Indian Standard specifications are not mandatory for classification, which is governed by the General Rules of Interpretation, Section and Chapter Notes and the HSN, and declined to examine the applicant’s arguments on BIS standards. It added that under Section 103 of the CGST Act, rulings of other advance ruling authorities bind only those applicants and their jurisdictional officers, so the applicant’s reliance on them was unjustified.

The ruling is based exclusively on the applicant’s submissions, test reports and documents, and is subject to their authenticity.

2026-juristway.com-3269-AAR(Gujarat)-GST