GST Classification of Fusible Interlining Fabrics Under Chapter 52
The Gujarat Authority for Advance Ruling confirmed that partially coated cotton fusible interlining fabrics fall under Chapter 52, not Chapter 59.
- Ruling
- ADVANCE RULING NO. GUJ/GAAR/R/2025/45 dated 03.11.2025
- Dated
- 03 Nov 2025
- 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
- The company asked for the correct GST classification of cotton fusible interlining fabrics.
- The product uses a partial, non-continuous plastic coating on cotton fabric.
- The Authority ruled the product belongs under Chapter 52, covering cotton fabrics.
In short
The company asked the Gujarat Authority for Advance Ruling (GAAR) to decide if their cotton fusible interlining fabric belongs in Chapter 52 or Chapter 59 of the GST tariff. Because the fabric is only partially coated with plastic, it does not meet the criteria for Chapter 59, which typically covers fully impregnated or coated textiles. The Authority confirmed that since the fabric is mostly cotton and the coating is not continuous, it remains classified as a cotton product under Chapter 52.
What has changed
How it worked before
Businesses were previously uncertain about this classification, with some earlier rulings incorrectly placing these partially coated fabrics under Chapter 59.
What has changed
The Authority clarified that partially coated fabrics are excluded from Chapter 59. For manufacturers, this means these goods should be taxed under the rates applicable to cotton fabrics in Chapter 52 rather than the category for coated textiles.
Who this affects
Manufacturers and traders of fusible interlining fabrics or similar partially coated textile products.
An example
A textile manufacturer produces a cotton-based interlining with a light, dotted plastic coating. They were unsure if they should use the Chapter 59 tax rate. Based on this ruling, they can now argue that their product is a Chapter 52 cotton fabric because the coating is partial and the material is primarily cotton.
What you should do
This ruling is only binding on the company that asked and its specific tax office. If you manufacture similar products, use this as a reference for your own classification, but consult with your tax advisor to confirm your specific product's composition and coating type.
If you do nothing
If you classify your goods incorrectly, you risk paying the wrong tax rate, which can lead to demands for unpaid tax, interest, and penalties. A tax officer may disagree with your classification if your product does not match the specific technical criteria of this ruling. Relying on a ruling that does not apply to your specific facts can leave you vulnerable during an audit.
The terms explained
- Fusible Interlining
- A type of fabric used as a stiffening layer inside garments that sticks to the outer fabric when heated.
- Chapter 52
- A section of the GST tariff that specifically covers cotton fabrics.
- Chapter 59
- A section of the GST tariff that covers impregnated, coated, covered, or laminated textile fabrics.
The ruling in detail
Authority for Advance Ruling
M/s. Girish Pravinchandra Rathod (Jay Ambe)
ADVANCE RULING NO. GUJ/GAAR/R/2025/45 dated 03.11.2025 · Gujarat
Questions before the authority
- Whether the product 'Fusible Interlining Fabrics of Cotton' is correctly classifiable under Chapter 52 or Chapter 59?
Facts
The applicant manufactures fusible interlining fabrics of cotton by coating one side of the cotton fabric with pulverised plastic powder using a dot matrix printing process. This process creates a partial, non-continuous layer of plastic that does not make the fabric completely impervious. The applicant sought a ruling on the correct classification of this product following a Gujarat High Court order that set aside previous rulings classifying it under Chapter 59.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification of Fusible Interlining Fabrics of Cotton | Chapter 52 Based on the product containing 85% or more of cotton. |
The Authority ruled that the product is correctly classifiable under Chapter 52. This decision follows the Gujarat High Court's determination that partially coated fabrics do not fall under Chapter 59, but rather under the chapter corresponding to the textile material used.
Reasoning
The Authority relied on the Gujarat High Court's order, which held that partially coated fabrics are excluded from Chapter 59 and should be classified under Chapters 50 to 55, 58, or 60. The test report from ATIRA confirmed the fabric is partially coated, porous, and contains 85% or more cotton. Consequently, the Authority determined that the product falls under Chapter 52, which covers cotton fabrics. The Authority also referenced Circular No. 5/89, which clarified that prior to the introduction of specific notes in Chapter 59, such fabrics were classified based on their textile material.
Provisions relied on
- Chapter 52 of the GST Tariff
- Chapter 59 of the GST Tariff
- Chapter Note 2(a) of Chapter 59
- Circular No. 5/89 dated 15.06.1989
For the practitioner
This ruling settles the classification of fusible interlining fabrics of cotton as **Chapter 52** goods, confirming they are not classifiable under Chapter 59. It is highly useful for manufacturers of similar partially coated textile products to avoid incorrect classification under Chapter 59. Practitioners should note that this decision is **fact-specific** to products containing 85% or more cotton and having a partial, non-continuous coating.
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/45_girish_pravinchandra_rathod_compressed.pdf
Legibility of the scan, as read: high.
Prepared 15-10-2026.
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