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Advance rulings (AAR) West Bengal

GST Classification of Polypropylene Leno Bags: West Bengal Advance Ruling

The West Bengal Authority for Advance Ruling confirmed that specific Polypropylene Leno bags are classified as textile articles under HSN 63053300.

Ruling
19/WBAAR/2018-19 dated 28.09.2018
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. The company asked for the correct GST classification of Polypropylene Leno bags.
  2. The authority ruled these bags fall under Tariff Sub Heading 63053300.
  3. Classification depends on strip width under 5mm and no plastic coating.

In short

The company asked the West Bengal Authority for Advance Ruling to clarify if their Polypropylene (PP) Leno bags, used for packing produce, should be taxed as textile products or plastic goods under the Goods and Services Tax (GST).

What has changed

How it worked before

Manufacturers were uncertain whether these bags belonged under Chapter 39 as plastic articles or Chapter 63 as textile articles, leading to potential confusion in tax rates.

What has changed

The authority decided that because the strips used are under 5mm wide and lack plastic coating, they qualify as textile articles under HSN 63053300. This provides a clear tax category for manufacturers meeting these specific technical standards.

Who this affects

Manufacturers of Polypropylene Leno bags or similar woven synthetic packaging materials.

An example

A manufacturer in Gujarat produces PP Leno bags with 2.5mm strips and no plastic coating. They wonder if they should follow this West Bengal ruling to classify their goods under 63053300. While the ruling provides helpful guidance on how the department interprets the law, the manufacturer should consult their own tax advisor to confirm if their local tax officer agrees with this classification.

What you should do

If you manufacture similar bags, review your production specifications against the 5mm strip width and coating criteria. Remember that an advance ruling only binds the company that asked and its specific tax office; it is not a universal law for your business.

If you do nothing

If you assume this ruling applies to you and classify your goods incorrectly, you risk a tax demand or penalty if your local officer disagrees. Tax authorities may view an incorrect classification as an attempt to pay lower taxes than required. Always verify your specific product's classification with your own tax professional.

The terms explained

HSN
Harmonized System of Nomenclature is a standardized system used to classify goods for taxation purposes.
Impregnated
A process where a material is soaked or filled with another substance, such as plastic, to change its properties.
Tariff Sub Heading
A specific code within the tax schedule that determines the GST rate applicable to a particular type of product.

The ruling in detail

Authority for Advance Ruling

RLJ Woven Sacks Pvt. Ltd

19/WBAAR/2018-19 dated 28.09.2018 · West Bengal

Questions before the authority

  • Classification of Polypropylene Leno Bags under the CGST/WBGST Acts, 2017

Facts

The applicant manufactures Polypropylene Leno Bags primarily used for packing vegetables and fruits. The manufacturing process involves extruding a mixture of Polypropylene, Linear Low Density Polyethylene, and Colour Master Batch into strips, which are then woven into fabric and stitched into bags. The applicant sought a ruling on the correct classification of these specific bags.

Ruling

QuestionWhat the authority ruled
Polypropylene Leno Bags63053300
Must use strips <= 5mm and have no plastic coating or lamination

The authority ruled that the bags are classifiable under Tariff Sub Heading 63053300. This classification is contingent upon the bags being made from strips not exceeding 5mm in width and lacking any impregnation, coating, covering, or lamination with plastics.

Reasoning

The classification turned on whether the product qualifies as a textile article under Section XI or as a plastic article under Chapter 39. The authority noted that Note 1(g) to Section XI excludes strips exceeding 5mm from being considered textile materials, and Note 1(h) excludes bags impregnated or coated with plastics. Based on IS 16187:2014, which specifies a width of 2.0 to 2.5 mm for these bags, the product falls within the **textile classification** for man-made materials. Consequently, the bags are classified under **Tariff Sub Heading 63053300** provided they meet the specified technical criteria.

Provisions relied on

  • Section 97(2)(a) of the GST Act
  • Note 2(p) of Chapter 39 of the GST Tariff
  • Note 1(g) to Section XI of the Tariff Act
  • Note 1(h) to Section XI of the Tariff Act
  • Tariff Sub Heading 39232990
  • Tariff Sub Heading 63053300
  • IS 16187:2014

For the practitioner

This ruling provides clarity for manufacturers of PP Leno bags regarding their classification under the GST tariff. It confirms that such bags qualify as textile articles under HSN 63053300, provided the constituent strips are 5mm or less in width and the fabric is not coated or laminated. Practitioners should note that this ruling does not apply to bags that are impregnated or coated with plastics, which would likely fall under Chapter 39.

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/wb_19_2018-19_dt_28.09.18_rljwspl.pdf

Legibility of the scan, as read: high.

Prepared 21-10-2026.

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Does this ruling mean I can automatically use HSN 63053300 for my bags?

No. An advance ruling is only binding on the company that requested it. You should use this as a reference for how the department thinks, but confirm your specific product's classification with your own tax advisor.

What if my bags are coated with plastic?

The ruling specifically excludes bags that are impregnated, coated, or laminated with plastics. If your bags have these features, they likely fall under a different category, such as Chapter 39.

Is this ruling binding on my local tax officer?

No. An advance ruling is not a law that applies to all businesses. Your local tax officer is not legally required to follow a decision made for a different company in a different state.

What happens if my strips are wider than 5mm?

The ruling relies on the fact that the strips are under 5mm. If your strips exceed this width, the classification criteria change, and the product may no longer qualify as a textile article under this heading.