Reformate Classifiable Under Tariff Item 2707 50 00 as Aromatic-Rich Petroleum Product

Centax Editorial Board

May 28, 2026

• 2 min. read

Case Details: Mangalore Refinery and Petro Chemicals Ltd. vs. Commissioner of Customs, Mangaluru (2026) 42 Centax 340 (Tri.-Bang)

Judiciary and Counsel Details

- Dr D.M. Misra, Member (J) & Mrs R. Bhagya Devi, Member (T)
- S/Shri Ravi Raghavan, Ms Purvi Asati & Ms Ashwini Nag, Advocates, for the Appellant.
- Shri P.R.V. Ramanan, Special Counsel (AR), for the Respondent.

Facts of the Case

The appellant, engaged in petroleum refinery operations, imported Reformate during a period when its manufacturing units were shut down for maintenance activities. The appellant classified the imported product under Tariff Item 2707 50 00 of the Customs Tariff. However, the department rejected this classification and reclassified the imported goods under Tariff Item 2710 12 19. The department’s reasoning was that Reformate was classifiable as light oil and preparations akin to motor spirit. The department further relied upon test reports, tender documents, and the product’s flash point to support the claim that the imported goods satisfied the requirements of Heading 2710. The appellant countered this by citing the decision of the tribunal in Reliance Industries Ltd. (2024) 15 Centax 183 (Tri.-Bom.), which was affirmed by the Supreme Court in (2024) 15 Centax 184 (S.C.). The appellant contended that Reformate was an aromatic-rich petroleum product, specifically classifiable under Tariff Item 2707 50 00. The matter was placed before the CESTAT.

CESTAT Held

The CESTAT held that Reformate was a highly aromatic-rich product obtained from the processing of petroleum and that aromatic constituents formed the major component of the imported goods. It was observed that the expression ‘similar products’ used in Heading 2707 also included products obtained from the processing of petroleum and was not confined only to products derived from coal tar distillation. Furthermore, it was held that the expression ‘at 250ºC’ occurring in Tariff Item 2707 50 00 should be read as ‘by 250ºC’, and therefore the imported product satisfied the requirements of the tariff entry. It was also noted that Heading 2710 excluded preparations specifically covered elsewhere under the Customs Tariff, and Reformate was specifically included under Tariff Item 2707 50 00. Consequently, the ruling concluded that reopening the classification issue concerning identical products could not be justified once the earlier tribunal decision, affirmed by the Supreme Court, had attained finality, leading to the setting aside of the impugned order.