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India FTA Duty Toolkit

Rules of Origin for poly(vinyl chloride) binders for pigments — Dubai (UAE) to India

HS 39041010 · POLYMERS OF VINYL CHLORIDE OR OF OTHER HALOGENATED OLEF · Rules of Origin & preferential rate

Data last updated: · MFN duty & IGST verified against ICEGATE (Indian Customs EDI). Rules of Origin per CEPA Annex 3B. Verify your exact HS line before filing.

CEPA benefit is quota-limited

The India–UAE CEPA concession on this line is a tariff-rate quota, not an open rate: 5% basic customs duty applies within the annual quota — a volume shared across HS 39041010, 39041020, 39041090, 39042100 — and imports beyond it pay the 7.5% rate shown below. Annex 2A modality: "TR (Year-wise TRQ)" (Annex 2A-83); Year 5 of the schedule is calendar 2026. Annex 2A names the quota but states no volume for it. source ↗

CEPA eligible
Yes, within quota
Value addition (RVC)
40%
Tariff-classification change
CTSH Annex 3B rule set at chapter level — it covers the whole chapter, not this code alone
MFN → CEPA basic duty
7.5% → 5% in quota / 7.5% beyond

Rule of Origin (CEPA Annex 3B, primary source): CTSH + VA 40% (CEPA Annex 3B Product-Specific Rule; tariff-shift AND value addition both required).

Qualifying under the Rules of Origin

To claim the CEPA preference on poly(vinyl chloride) binders for pigments (HS 39041010), the goods must qualify as UAE-originating. The Product-Specific Rule (Annex 3B) is "CTSH + VA 40% (CEPA Annex 3B Product-Specific Rule; tariff-shift AND value addition both required)": the goods must undergo a change of tariff sub-heading (CTSH) AND add at least 40% regional value content — both conditions, not either/or. Read that rule for what it is: Annex 3B supplies it at chapter level, so it governs hundreds of eight-digit codes rather than this one. It is the correct rule to apply, and it is also the place to check for a more specific carve-out before committing to a claim. Qualifying on origin is necessary but not sufficient here, because India's offer on this line is a tariff-rate quota: a shipment with a valid Certificate of Origin still pays 7.5% once the year's volume is drawn, and the quota is allocated rather than claimed at the border. PVC binder grades are used in pigment dispersions, coatings and specialty formulations. Annex 2A puts this line inside a year-wise tariff-rate quota shared with suspension-grade PVC (39041020), other PVC (39041090) and non-plasticised PVC (39042100): 5% basic customs duty within the quota against 7.5% outside it. The agreement does not publish the volume for this group, which is itself worth knowing — the opportunity cannot be sized from the schedule, so confirm the allocation with DGFT. The 18% IGST is recoverable. PVC is heavily anti-dumping-exposed, and unlike a CEPA claim an anti-dumping duty cannot be avoided by documentation. Two further points. Because Annex 2A names the quota without publishing a volume for this vinyl group, an importer cannot size the opportunity or judge how much has been drawn — the allocation has to come from DGFT rather than the schedule. And origin is a separate test from the quota: a sub-heading change plus 40% value addition, which UAE polymerisation meets and drumming or blending imported resin does not. A valid Certificate of Origin filed through the eCoO 2.0 system must accompany the shipment; without it, customs charges the 7.5% MFN rate instead of the preference.

Check your own figures in the Rules of Origin (RVC) qualifier. Qualifying is only half of it — the preference is claimed with a Certificate of Origin, issued in the UAE before shipment or retrospectively within 12 months.

Frequently asked questions

Does poly(vinyl chloride) binders for pigments qualify for India–UAE CEPA?
Yes, but the benefit is capped: India's offer on this line is a tariff-rate quota of 5% basic customs duty within the annual quota, and the 7.5% rate beyond it. Origin still has to be proved: the Annex 3B rule is "CTSH + VA 40% (CEPA Annex 3B Product-Specific Rule; tariff-shift AND value addition both required).".
What is the Rule of Origin for poly(vinyl chloride) binders for pigments?
Per CEPA Annex 3B: CTSH + VA 40% (CEPA Annex 3B Product-Specific Rule; tariff-shift AND value addition both required).. RVC% = [(FOB − value of non-originating materials) / FOB] × 100 (FOB basis).
What proof is needed at import?
A preferential Certificate of Origin filed through eCoO 2.0, presented at customs before clearance. Without it, the 7.5% MFN duty applies.