Circular No.ES/ 247 / 2018-19                                                                               10^th October, 2018

To: Members of the Council

Sub. : Classification of e-seals under Heading 8309

Dear Member,

We would like to inform you that CBIC has issued Instruction No. 16/2018- Customs dated 8^th October, 2018 classifying e-seals under Heading 8309.

It has been noticed by the Board that the RFID e-seals for sealing of containers are being classified variably at different locations.

Hence, Board has examined the issue of classification of RFID seals with respect to the functionality, SAFE framework standards provided by the World Customs Organization (WCO) regarding various kinds of seals (including e-seals) and the HSN Explanatory Notes.

ISO 181852 defines e-seal as “Read-only, non-reusable freight container seal conforming to the high security seal defined in ISO/PAS 17712 (standard for mechanical seals) and conforming to ISO 18185 or revision thereof that electronically evidences tampering or intrusion through the container door”.

In view of the above, CBIC has clarified the following-

• Electronic seals are seals only but with electronic add on (RFID) to detect security breach.
• E-seals merit classification under the Heading 8309 which covers- Stoppers, caps and lids (including crown corks, screw caps and pouring stoppers), capsules for bottles, threaded bungs, bung covers, seals and other packing accessories, of base metal.
• E-seals warrant classification under the tariff item 83099030.

Members may kindly make a note of the above.

Thanking you,

Yours faithfully,

S. BALARAJU
EXECUTIVE DIRECTOR