PVC Raincoats Classified As Plastic Articles And Not Textile Apparel, Attract 18% GST: Gujarat AAR

The ruling came on an application filed by a Gujarat-based manufacturer of PVC and plastic raincoats. The applicant had sought clarity on whether PVC raincoats should be taxed at 5% as apparel or at 18% as articles of plastic.

The applicant is engaged in the business of manufacture, resale, deal, purchase, import, export, process all kinds and nature of plastics, rainwear, rubberized rainwear, nylon rainwear and all other items of plastics clothing, plastic sheeting and other rainwear accessories.

The applicant argued that raincoats are commonly understood as clothing items and should therefore fall under the GST entries applicable to garments, which carry a lower tax rate. It was also contended that PVC raincoats are wearable apparel and compete in the same market as textile raincoats.

The Gujarat AAR examined the manufacturing process in detail and noted that PVC raincoats are made by cutting plastic sheets and joining them through heat sealing or chemical bonding, rather than by weaving fabric. The Authority observed that PVC sheets are not textile fabric and that the final product cannot be considered a woven garment.

Relying on tariff notes and explanatory provisions, the AAR bench ruled that plastic raincoats are specifically covered under the entry for “other articles of plastics,” which includes raincoats made by sealing plastic sheets. The ruling was pronounced by the Gujarat AAR bench comprising Vishal Malani (CGST Member) and Sushma Bora (SGST Member).

Accordingly, the Authority ruled that PVC raincoats fall under HSN 3926 and attract GST at the rate of 18%, rejecting the applicant's claim for the lower apparel rate.

Advance Ruling No.: GUJ/GAAR/R/2025/51

Dated: 24.11.2025 (GUJARAT AAR)