The Rajasthan Authority for Advance Ruling has held that Rubberised Cork Sheets and Agglomerated Cork Sheets manufactured by combining cork granules (30.99%) with polymer/rubber (42.47%), chemicals, processing oil and fillers are correctly classifiable under Tariff Item 45041010 of the Customs Tariff Act and are covered under Serial No. 310 of Schedule-I of Notification No. 09/2025-CT (Rate) at 5% GST (2.5% CGST + 2.5% SGST) under the GST 2.0 rate structure. The ruling by Members Mahipal Singh and Dr. Akhedan Charan in RAJ/AAR/2026-27/16 (M/s Balasaria Agencies Pvt. Ltd., decided 19.08.2026) rejected the Department’s contention that the predominant weight of polymer meant the product should be classified under Chapter 40 (Rubber) at 18%.
The AAR found that Heading 4504 reads ‘Agglomerated cork (with or without a binding substance)’ and prescribes no threshold — whether by weight, volume or otherwise — for the proportion which the binding substance may bear to the cork, and names no particular class of binder to the exclusion of others. Where the heading itself draws no line, the AAR held it could not draw one. The court further held that cork is the material being agglomerated and the polymer system performs the office of holding the agglomerated granules together — cork was not employed as a filler in a rubber compound. On the question of whether only ‘natural’ cork products could benefit from the rate entry, the AAR noted that the word ‘natural’ appears in Headings 4501, 4502 and 4503 but is noticeably absent from Heading 4504 — agglomerated cork is, by definition, reconstituted cork and cannot be natural cork. To read Entry 310 as available only for natural cork would render it futile.
- 2026-juristway.com-2635-AAR(Rajasthan)-GST | AAR Rajasthan | RAJ/AAR/2026-27/16 | 19.08.2026