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CBIC: Deferment of implementation date of Circular No. 08/2023 providing for identification of products/equipment prescribed in tariff item 85176290 and 85176990
CBIC: Deferment of implementation date of Circular No. 08/2023 providing for identification of products/equipment prescribed in tariff item 85176290 and 85176990

April 3, 2023

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We have made a representation to Central Board of Indirect Taxes and Customs (CBIC) highlighting issues being faced by the industry in complying with Circular No. 08/2023 dated March 13, 2023 (Circular), which is effective from April 1, 2023. The Circular require importers to provide an alpha-numeric code/identifier in the bill of entry for identification of products/equipment prescribed in tariff item 85176290 and 85176990 from the time of filing of import declarations.

To comply with these requirements, companies will need to assess their products IDs that are imported (which may be hundreds or even thousands in some cases) and change the processes to submit the above information at the time of filing import declarations. However, considering that the Circular was issued in mid-March, Industry has very little time to make changes in their internal systems and comply with these requirements. For a smooth and successful implementation of a critical business change of this magnitude, it is imperative that businesses are given adequate time to configure and test their systems.

Further, for a given product, there could be multiple technologies that can be used as identifiers. There could also be scenarios where products classified under “Others” tariff codes may have a combination of one or more technologies indicated in Annexure 2 of the Circular. Absence of clarity on these aspects will result in increased risk of queries being raised by field formations on re-classification of products. There is also an apprehension that queries will be raised on the exemptions claimed by the industry while importing such products, thereby impacting business competitiveness. 

To address the above issues, we have requested CBIC to defer implementation of the Circular by at least 6 months. This will enable the industry to adequately plan and effect changes in their internal system for smooth implementation of the Circular. Government should also hold consultations along with the industry to understand the challenges, convergence in technologies, etc. This will provide clarity to the industry.


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Tejasvi

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