TMI Blog2020 (12) TMI 796X X X X Extracts X X X X X X X X Extracts X X X X ..... bon black. It is only the rubber component of the tyre which is converted into Pyrolysis Oil, which can be used for heating purposes and as a liquid fuel. Applicant has submitted that Pyrolysis oil can also be sold as a liquid fuel - Since there is no specific and separate schedule entry prescribed for Tyre pyrolysis oil , we are required to classify the said product. The Applicant vide email dated 20.11.2020, has made submissions which appear to have been sourced from the internet. However they have not made any submissions in respect of the chemical composition of their product nor have submitted any test report which shows the composition of their product - In view of non-submission of details, this Authority cannot pass a Ruling on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oyal Carbon Black Pvt. Ltd., the applicant, has raised the question regarding classification of Tyre Pyrolysis Oil and the rate of tax applicable thereon . The manufacturing process and a test report in respect of the impugned product i.e. Pyrolysis Oil is submitted. 2.2 As per the submission, Tyre is made out of 30% to 35% Carbon, 35% to 40 % rubber and 10% to 15% steel. Once the tyres are removed from the car it becomes a waste. This waste is recycled by the applicant and the rubber component of the tyres is converted into oil which can be used for heating purposes and can be called as pyrolysis oil. Like Biodiesel, Pyrolysis oil can also be sold in similar applications as a liquid fuel. 2.3 Applicant has submitted that pyrolysis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al officer has made additional submission on 10.02.2020, and stated therein that, according to Annexure A and B provided, the applicant is into complete recycling of used tyres and in such a process of recycling, one of the byproducts is pyrolysis oil which is sold as liquid fuel. In GST there is no separate entry of pyrolysis oil which is the end product of waste tyre. The oil is widely used as industrial fuel to substitute furnace oil or industrial diesel. Applicant has requested to classify Pyrolysis oil either as Biodiesel (HSN 3826) or as Marine fuel (IISN 2710). 3.3 Biodiesel is a Renewable fuel that can be produced from a wide range of vegetable oils or animal fats and may be used either as a replacement for or as a component of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oved at the start of the fractional distillation process. Heavier petroleum products like diesel fuel and lubricating oil are much less volatile and distill out more slowly, while bunker oil is literally the bottom of the barrel; in oil distilling, the only things denser than bunker fuel are carbon black feedstock and bituminous residue (asphalt), which is used for paving roads and sealing roofs. Biodiesel is typically made by chemically reacting lipids (all organic sources) and pyrolysis oil mentioned above is made of inorganic sources. 3.5 In view of the above it is seen that Pyrolysis oil is neither made of any vegetable oil or animal fat and the production process of pyrolysis oil does not involve any kind of distillation of any pet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... said process of recycle, along with other products like Iron and Steel and carbon black. It is only the rubber component of the tyre which is converted into Pyrolysis Oil, which can be used for heating purposes and as a liquid fuel. Applicant has submitted that Pyrolysis oil can also be sold as a liquid fuel 5.3 Since there is no specific and separate schedule entry prescribed for Tyre pyrolysis oil , we are required to classify the said product. 5.4 Applicant has submitted that pyrolysis oil should be classified as a Biodiesel falling under HSN 3826 since it is derived from the rubber part of a tyre, which is renewable in nature or alternatively, it should be classified as Marine Fuel falling under HSN 2710 as its specifications mee ..... X X X X Extracts X X X X X X X X Extracts X X X X
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