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Advance rulings (AAR) West Bengal

GST Classification of HDPE Woven Tarpaulin Laminated with Plastic

West Bengal tax authority ruled plastic-laminated HDPE woven tarpaulins are classified as plastics, not textile products under GST.

Ruling
12/WBAAR/2018-19 dated 20/07/2018
Dated
20 Jul 2018
Authority
Authority for Advance Ruling

This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.

The short version

  1. Company asked if HDPE woven tarpaulins fall under textile heading HSN 6306.
  2. Authority ruled tarpaulins laminated with plastic layers are excluded from textile classification.
  3. Lamination with plastic film places the product under plastic goods Chapter 39.
  4. Certificates from Ministry of Textiles do not override GST classification rules.

In short

East Hooghly Polyplast Pvt Ltd asked whether High Density Polyethylene (HDPE) woven tarpaulins laminated on both sides with plastic film should be classified under textile heading HSN 6306. The company argued that since the base material is woven and recognized by textile authorities, it should count as a textile tarpaulin for Goods and Services Tax (GST) purposes. The tax authority examined the product's construction to decide whether it belongs under textiles or plastic products.

What has changed

How it worked before

Many manufacturers assumed HDPE woven tarpaulins were textile products because they were made from woven fabric and backed by licenses from the Ministry of Textiles or Bureau of Indian Standards (BIS).

What has changed

The Authority for Advance Ruling (AAR) under order 12/WBAAR/2018-19 decided that plastic-laminated HDPE woven tarpaulins cannot use textile heading HSN 6306. Because the woven fabric is laminated on both sides with plastic film, GST tariff section notes strictly remove it from textiles and place it under plastic goods in Chapter 39. In practice, manufacturers cannot claim textile tax classifications for plastic-coated or laminated tarpaulins.

Who this affects

Manufacturers and traders making or selling HDPE woven tarpaulins, plastic laminated sheets, or plastic-coated woven fabrics.

An example

A plastic manufacturing unit in Gujarat makes heavy-duty tarpaulins by weaving HDPE tapes and laminating both sides with plastic film to make them waterproof. The owner wants to clear goods under HSN code 6306 to claim textile classification, pointing to a Ministry of Textiles license. Based on ruling 12/WBAAR/2018-19, the tax authority considers plastic-laminated tarpaulins to fall under plastic heading HSN 3926 instead. To prevent future tax disputes, the owner should seek professional tax advice or apply for an advance ruling.

What you should do

Check whether your woven tarpaulins are laminated or coated on both sides with plastic film. Remember that an advance ruling legally binds only the business that applied for it and their local tax officer. If you manufacture similar goods, consult a GST professional or apply for your own advance ruling before changing your tax rate or tariff code.

If you do nothing

Assuming this ruling automatically applies to your business without reviewing your exact manufacturing process creates tax risks. If a tax officer audits your business and finds you classified plastic-laminated tarpaulins under textile codes, they can issue back-dated tax demands. You could also face interest and penalties for using an incorrect Harmonized System of Nomenclature (HSN) code.

The terms explained

HSN Code
A standardized international product coding system used under GST to categorize goods and decide their applicable tax rates.
Advance Ruling
A written decision issued by tax authorities to a specific applicant clarifying how tax law applies to their product or transaction.
Section Notes
Binding legal instructions at the start of each section in the GST tariff schedule that specify which products are included or excluded.

The ruling in detail

Authority for Advance Ruling

East Hooghly Polyplast Pvt Ltd

12/WBAAR/2018-19 dated 20/07/2018 · West Bengal

Questions before the authority

  • Whether 'HDPE Woven Tarpaulin' will be classified under HSN 6306 of the GST Tariff.

Facts

The Applicant is a manufacturer of tarpaulins made from High Density Polyethylene (HDPE) woven fabric as well as plastic tarpaulins. The manufacturing process involves producing HDPE tapes from granules, weaving the tapes into fabric, and laminating both sides of the woven fabric with Low Density Polyethylene (LDPE/LLDPE) film. The Applicant claimed that HDPE woven tarpaulins are textile articles and sought classification under HSN 6306 relying on licenses from BIS and the Ministry of Textiles.

Ruling

QuestionWhat the authority ruled
Classification of HDPE Woven Tarpaulin under HSN 6306Will not be classified under HSN 6306
Excluded from Chapter 63 due to plastic lamination on both sides

The Authority held that tarpaulins made of HDPE woven fabrics **will not be classified under HSN 6306** of the GST Tariff. Because the product is laminated on both sides with LDPE sheets or film, it is excluded from Chapter 63 pursuant to Section Note 1(h) of Section XI.

Reasoning

The decision turned on the rules for interpretation under Notification No. 1/2017-CT (Rate) and the Section Notes of the First Schedule to the Customs Tariff Act, 1975. Note 1(h) to Section XI explicitly excludes woven fabrics that are impregnated, coated, covered, or laminated with plastics of Chapter 39 from Chapters 50 to 63. Since the Applicant's tarpaulin is a laminate of woven HDPE tapes and LDPE plastic sheets, it **cannot fall under Chapter 63** regardless of industry designations or licenses issued by the Ministry of Textiles or the Bureau of Indian Standards.

Provisions relied on

  • Section 97(2)(a) of the CGST Act, 2017
  • Section 97(2)(a) of the WBGST Act, 2017
  • Notification No. 1/2017-CT (Rate) dated 28.06.2017
  • Note 1(g) to Section XI of the Customs Tariff Act, 1975
  • Note 1(h) to Section XI of the Customs Tariff Act, 1975
  • HSN 6306
  • HSN 3926 90 99

For the practitioner

This ruling establishes that HDPE woven tarpaulins laminated with plastic layers are excluded from textile classification under HSN 6306 and fall under Chapter 39. Practitioners should remember that **tariff Section Notes override external certifications** from BIS or the Ministry of Textiles for GST classification.

Source

This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.

Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/order_no._12_of_fy_19_dated_20072018.pdf

Legibility of the scan, as read: high.

Prepared 20-10-2026.

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Is this advance ruling binding on all tarpaulin manufacturers in India?

No, an advance ruling only binds the specific applicant and their concerned tax officer. Other businesses can use it to understand how the tax department views the issue, but it is not an automatic nationwide law.

Can a license from the Ministry of Textiles prove my product is a textile under GST?

No, tax authorities rely strictly on GST tariff section notes and rules of interpretation. Certifications or approvals from non-tax ministries do not override GST classification rules.

Why are laminated HDPE tarpaulins excluded from textile HSN 6306?

The section notes of the tariff explicitly exclude woven fabrics that are coated or laminated on both sides with plastic. Because plastic lamination alters the outer layer, the product falls under plastic goods in Chapter 39.

What should I do if my tax officer challenges my tarpaulin GST classification?

Gather detailed product composition charts and lab test reports showing whether your product has plastic lamination. You should consult a GST advisor to review your HSN code and determine if filing for an advance ruling is necessary.