Customs Tribunal Upholds Classification of Zinc EDTA as Fertilizer, Sets Aside Revenue's Reclassification

CESTAT Chennai Bench Rules in Favor of Coromandel International Ltd., Affirms Zinc EDTA's Classification Under "Other Fertilizers"

In a significant ruling dated December 2, 2025, the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) Chennai, set aside the orders of the Commissioner of Customs (Appeals-II) that sought to reclassify Zinc EDTA, imported by M/s Coromandel International Ltd., under a different tariff heading. The Tribunal upheld the classification of Zinc EDTA under Customs Tariff Item (CTI) 3105 9090 as "Other Fertilizers," rejecting the Department's attempt to classify it under CTI 2922 4990 as "Salts of Amino Acids."

The Tribunal, comprising Mr. M. Ajit Kumar and Mr. Ajayan T.V, emphasized the importance of judicial discipline and adherence to binding precedents, noting that the burden of proof to alter the classification lay with the Revenue, which it failed to discharge.

Coromandel International Ltd., a leading player in the fertilizer industry, had challenged the orders-in-appeal that upheld the Revenue's reclassification of Zinc EDTA, arguing that the goods are chelated micronutrient fertilizers containing essential elements such as nitrogen, which are absorbed by plants to improve growth. The Tribunal concurred with the appellant's stance, citing previous judgments, including its own decision in the appellant's earlier case, which had attained finality as it was not appealed by the Revenue.

The Tribunal's decision highlighted the presence of nitrogen in Zinc EDTA as a deliberate and essential constituent, thereby justifying its classification as a fertilizer. It also criticized the Department for failing to conduct proper chemical tests to substantiate its claims, relying instead on external opinions and internet sources.

The ruling reiterates the necessity for appellate authorities to follow judicial precedents to prevent undue harassment and administrative chaos, a principle underscored by the Supreme Court. The Tribunal expressed concern over the disregard for judicial discipline, warning that such practices could lead to unnecessary litigation and strain on judicial resources.

The decision is expected to bring relief to importers of similar products, reaffirming the classification standards for agricultural inputs that are critical for enhancing crop productivity.

Bottom Line:

Classification of imported goods - Zinc EDTA imported by appellant is classifiable under Customs Tariff Item (CTI) 3105 9090 as "Other Fertilizers" and not under CTI 2922 4990. Judicial discipline requires adherence to binding precedent, and the burden of proof to change the classification lies squarely on the Revenue.

Statutory provision(s): Customs Tariff Act, 1975, Section 28(1) of the Customs Act, Section 111(m) and Section 112(a) of the Customs Act, Chapter 29, Chapter 31, CTI 3105 9090, CTI 2922 4990.

M/s. Coromandel International Ltd. v. Commissioner of Customs, (CESTAT)(Chennai)(Regional Bench) : Law Finder Doc Id # 2818088