Rules of Origin for cast-iron pans, not enamelled — Dubai (UAE) to India
HS 73239110 · TABLE · 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 eligible
- Yes
- 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
- 20% → 0%
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 cast-iron pans, not enamelled (HS 73239110), 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. Non-enamelled cast-iron cookware has grown well beyond a niche as Indian consumers move toward durable and traditional cooking surfaces. CEPA removes the 20% basic duty — a large cut for a consumer line, which makes the origin diligence proportionate rather than optional. The 40% value-content rule turns on where the iron was cast and finished; a UAE finisher seasoning or coating imported castings may fall well short, because casting is where the value sits. The Steel Quality Control Orders apply to this chapter, requiring BIS certification of the producing mill before clearance. Food-contact compliance and packaged-commodity labelling under the Legal Metrology Act then apply independently of duty, and the labelling has to be printed at origin rather than applied at the port. Given the 20% differential, verify the foundry location in writing rather than accepting a regional invoice as evidence of origin — a failed claim on that gap is an expensive correction. A valid Certificate of Origin filed through the eCoO 2.0 system must accompany the shipment; without it, customs charges the 20% 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 cast-iron pans, not enamelled qualify for India–UAE CEPA?
- Yes, if it meets the Annex 3B Product-Specific Rule "CTSH + VA 40% (CEPA Annex 3B Product-Specific Rule; tariff-shift AND value addition both required).": it must BOTH change tariff classification (CTSH) AND add at least 40% regional value content — both conditions are required, not either/or.
- What is the Rule of Origin for cast-iron pans, not enamelled?
- 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 20% MFN duty applies.