Outdoor playground equipment attracts 5% GST, gym equipment 18%, while bearings are classified separately under Heading 8482

ORDER

1. M/s. Sundek Sports Private Limited, Survey No.431/P2, Nr. 9 Steel Town, Changodar, Ahmedabad, Gujarat, [for short – ‘applicant’], is registered under GST and their GSTIN is 24AAYCS7908J1ZK. Subsequently, the applicant has shifted its premises to Plot No. 5, Sankalp Industrial Estate-2, Behind Kerala GIDC, Chiada, Ahmedabad, Gujarat – 382220.

2. The applicant is engaged in the supply of outdoor playground and outdoor fitness/gym equipment installed at parks, schools, gardens, municipalities and public spaces. Their products generally include: (i) Outdoor playground slides, wings, seesaws, climbers, multi-activity play stations, (ii) Outdoor gym equipment such as twisters, pull-up bars, cross-trainers, leg press etc. (iii) Spare parts required exclusively for the above equipment (platforms, seats, handles, bearings, brackets, fabricated structures etc.). These products are made of metal (MS/GI/SS) with powder coating, and in some cases, components are plastic/FRP/HDPE.

3. The applicant has further submitted that these products are supplied as equipment for physical exercise/outdoor games and not as toys for personal amusement. The applicant wishes to determine the correct classification (HSN) and the applicable GST rate especially in view of Notification No.09/2025-Central Tax (Rate) dated 17.09.2025 (effective from 22.09.2025), which supersedes earlier rate schedules and reorganizes goods into new schedules.

4. The applicant has asked the following question on Advance Ruling:

“1. What is the appropriate classification (HSN Code) under GST for:

2. What is the applicable GST rate for supply of each of the above products in light of Notification No.09/2025-Central Tax (Rate) dated 17.09.2025?”

5. The applicant’s interpretation of law is as under:

6. Personal hearing was granted on 08.04.2026 wherein Shri Pratik Parasrampuria, appeared on behalf of the applicant and reiterated the facts & grounds as stated in the application. During the course of hearing, the representative of the applicant was asked to submit supporting judgements if any and also the 12 digit HSN code of their products, if available at an early date.

7. The applicant vide e-mail dated 08.04.2026 has submitted a copy a judgement dated 14.12.2016 – Arihant Industrial Corpn. Ltd. v. CCE 2016-VIL-3228-CESTAT-MUM-CE issued by the Customs, Excise and Service Tax Tribunal, West Zonal Bench at Mumbai in the case of appeal (Appeal No. E/1868/06-Mum) filed by M/s. Arihant Industrial Corpn. Ltd. against OIA No. BFR/44/Th-II/06 dated 03.03.2006 issued by the Commissioner of Central Excise (Appeals) wherein it was held that items such as climbers and thrillers are used in children’s playgrounds and gardens, are sports goods for children and therefore fall under the classification of sports goods classifiable under Chapter 9506.

8. At the outset, we would like to state that the provisions of both the CGST Act and the GGST Act are the same, except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the CGST Act would also mean a reference to the same provisions under the GGST Act.

9. We have considered the submissions made by the applicant in their application for advance ruling as well as the submissions made both oral and written during the course of personal hearing. We have also considered the issue involved, the relevant facts & the applicant’s submission/views in respect of question on which the advance ruling is sought.

10. We find that the applicant is engaged in the supply of outdoor playground and outdoor fitness/gym equipment installed at parks, schools, gardens, municipalities and public spaces which include: (i) Outdoor playground slides, swings, see-saws, climbers, multi-activity play stations, (ii) Outdoor gym equipment such as twisters, pull-up bars, cross-trainers, leg press etc. (iii) Spare parts required exclusively for the above equipment (platforms, seats, handles, bearings, brackets, fabricated structures etc.). The applicant has stated that these products are made of metal (MS/GI/SS) with powder coating, and in some cases, components are plastic/FRP/HDPE. The applicant wants to know the appropriate classification (HSN code) under GST of: (a) Outdoor Playground Equipment, (b) Outdoor Gym Equipment, (c) Spare parts of Outdoor Playground Equipment and (d) Spare parts of Outdoor Gym Equipment. They also what to know the applicable GST rate for supply of each of the above products in light of Notification No.09/2025-Central Tax (Rate) dated 17.09.2025.

11. The applicant has opined that the products supplied by them are classifiable under Heading 9506 of the Customs Tariff Act, 1975, that they are covered under Schedule-I of Notification No.09/2025-Central Tax (Rate) dated 17.09.2025 and chargeable to tax @5%. Therefore, we find it prudent to refer to the Chapter Notes of Chapter 95 of the Customs Tariff Act, 1975, heading 9506 as well as HSN notes pertaining to the said heading. The same are reproduced for ease of reference:

1. This Chapter does not cover:

(ij) unmounted glass eyes for dolls or other toys, of heading 7018;

2. This Chapter includes articles in which natural or cultured pearls, precious or semi-precious stones (natural, synthetic or reconstructed), precious metal or metal clad with precious metal constitute only minor constituents.

3. Subject to Note 1 above, parts and accessories which are suitable for use solely or principally with articles of this Chapter are to be classified with those articles.

4. Subject to the provisions of Note 1, heading 9503 applies, inter alia, to articles of this heading combined with one or more items, which cannot be considered as sets under the terms of rule 3 (b) of the General rules for Interpretation of this schedule, and which, if presented separately, would be classified in other headings, provided the articles are put up together for retail sale and the combinations have the essential character of toys.

5. Heading 9503 does not cover articles which, on account of their design, shape or constituent material, are identifiable as intended exclusively for animals, for example, “pet toys” (classification in their own appropriate heading).

6. For the purposes of heading 9508:

Sub-heading 9504 50 covers:

Snow-skis and other snow-ski equipment:

9506 11 00 — Skis

9506 12 00 — Ski-fastenings (ski-bindings)

9506 19 00 — Other

Water-skis, surf-boards, sailboards and other water-sport equipment

9506 21 00 — Sailboards

9506 29 00 – Other

Golf clubs and other golf equipment:

9506 31 00 — Clubs, complete

9506 32 00 — Balls

9506 39 00 – Other

9506 40 00 – Articles and equipment for table-tennis

– Tennis, badminton or similar rackets, whether or not strung:

9506 51 00 — Lawn-tennis rackets, whether or not strung :

950659 — Other:

9506 59 10 – — Squash or racketball badminton rackets, whether or not strung

9506 59 90 – — Other

Balls, other than golf balls and table-tennis balls:

9506 61 00 — Lawn-tennis balls

9506 62 — Inflatable:

9506 62 10 Football

9506 62 20 Volley ball

9506 62 30 – — Basket ball

9506 62 90 – — Other

9506 69 — Other:

9506 69 10 – — Hockey ball

9506 69 20 – — Cricket ball

9506 69 30 – — Golf ball

9506 69 40 – — Rugby ball

9506 69 90 – — Other

9506 70 00 – Ice skates and roller skates, including skating boots with skates attached –

Other:

9506 91 — Articles and equipment for general physical exercise, gymnastics or athletics:

950691 10 – — Boxing equipment

9506 91 90 – — Other

9506 99 — Other:

9506 99 10 – — Badminton shuttle cocks

9506 99 20 – — Leg pads and bats for cricket

9506 99 30 – — Shoulder pads for football

9506 99 40 – — Hockey sticks and blades

9506 99 50 – — Polo sticks including blades, shafts and heads

9506 99 60 – — Sports net

9506 99 70 – — Tennis and badminton racket pressures

9506 99 80 – — Shin-guards and elbow or shoulders pads excluding those for football; waist, thigh and hip protective equipment

9506 99 90 – — Other

95.06- Articles and equipment for general physical exercise, gymnastics, athletics, other sports (including table- tennis) or out-door games, not specified or included elsewhere in this Chapter; swimming pools and paddling pools.

– – Snow-skis and other snow-ski equipment:

9506.11 — Skis

9506.12 — Ski-fastenings (ski-bindings)

9506.19 — Other –

Water-skis, surf-boards, sailboards and other water-sport equipment:

9506.21 — Sailboards

9506.29 — Other

– – Golf clubs and other golf equipment:

9506.31 — Clubs, complete

9506.32 — Balls

9506.39 — Other

9506.40 – Articles and equipment for table-tennis

– – Tennis, badminton or similar rackets, whether or not strung:

9506.51 — Lawn-tennis rackets, whether or not strung

9506.59 — Other –

Balls, other than golf balls and table-tennis balls:

9506.61 — Lawn-tennis balls

9506.62 — Inflatable

9506.69 — Other

9506.70 – Ice skates and roller skates, including skating boots with skates attached

– -Other:

9506 91 — Articles and equipment for general physical exercise, gymnastics or athletics

9506 99 — Other

This heading covers:

The heading excludes:

12. As per the applicant’s view, the items supplied by them, their specific description and proposed HSN is as under:

13. As per the submission of the applicant, the outdoor playground equipment supplied by them is slides, swings, see-saws, climbers, multi-activity play stations whereas the Outdoor gym equipment supplied by them is twisters, pull- up bars, cross-trainers, leg press etc. They have also submitted that the spare parts supplied by them which are required exclusively for the above equipment are platforms, seats, handles, bearings, brackets, fabricated structures etc. They have also stated that these products are made of metal (MS/GI/SS) with powder coating, and in some cases, components are plastic/FRP/HDPE. The applicant has submitted a copy of judgement dated 14.12.2016 – Arihant Industrial Corpn. Ltd. (supra) issued by the Customs, Excise and Service Tax Tribunal, West Zonal Bench at Mumbai in the case of of appeal (Appeal No. E/1868/06-Mum) filed by M/s. Arihant Industrial Corpn. Ltd. against OIA No. BFR/44/Th-II/06 dated 03.03.2006 issued by the Commissioner of Central Excise (Appeals) wherein it was held that items such as climbers and thrillers used in children’s playgrounds and gardens, are sports goods for children and therefore fall under the classification of sports goods classifiable under Chapter 9506.

14. We have gone through the Chapter Notes of Chapter 95, Heading 9506 and it’s tariff entries as well as the HSN notes pertaining to Heading 9506. We find that the products supplied by the applicant do not fall under the excluded list in Sr.No.1 of the Chapter Notes to Chapter 95. We also find that the said products do not fall under the excluded list as mentioned in the HSN notes to Heading 9506. Further, on going through the HSN notes to Heading 9506, we find that “Outdoor Gym equipment” would be covered under “(A) Articles and equipment for general physical exercise, gymnastics or athletics etc.” and the “Outdoor Playground equipment” would be covered under Sr.No.12 of ” (B) Requisites for other sports and outdoor games (other than toys presented in sets, or separately, of heading 95.03), e.g.” which reads as ” (12) Equipment of a kind used in children’s playgrounds (e.g., swings, slides, see-saws and giant strides). We further find that the decision dated 14.12.2016 – Arihant Industrial Corpn. Ltd. (supra) of CESTAT, West Zonal Bench, Mumbai in the case of Arihant Industrial Corpn. Ltd.Against OIA dated 03.03.2006 of Commissioner of Central Excise (Appeals) wherein it was held that items such as climbers and thrillers used in children’s playgrounds and gardens, are sports goods for children and therefore fall under the classification of sports goods classifiable under Chapter 9506 is squarely applicable to the applicant’s case. Therefore, the outdoor playground equipment supplied by the applicant such as slides, swings, see-saws, climbers, multi-activity play stations used in children’s playgrounds and gardens are sports goods for children and are classifiable under Heading 9506.

15. Heading 95 06 of Chapter 95 of the Customs Tariff Act, 1975 reads as “Articles and equipment for general physical exercise, gymnastics, athletics, other sports (including table-tennis) or out-door games, not specified or included elsewhere in this chapter, swimming pools and paddling pools”. We find that the said heading not only covers Articles and equipment for general physical exercise, gymnastics, athletics but also covers a wide range of sports equipment/goods for indoor and outdoor sports as can be seen from the various tariff entries falling under the said heading. We find that sub-heading 950691 covers “Articles and equipment for general physical exercise, gymnastics or athletics”. We, therefore, find that “Outdoor Gym Equipment” are appropriately covered under Sub-heading 95 069190 (others) of the Customs Tariff Act, 1985. Further, since, we do not find any specific entry for “Outdoor Playground Equipment” supplied by the applicant in any of the tariff entries under heading 9506, we find that it would be aptly covered under sub-heading 95 069990 (others). Further, since Sr.No.3 of Chapter Notes to Chapter 95 reads as “3. Subject to Note 1 above, parts and accessories which are suitable for use solely or principally with articles of this Chapter are to be classified with those articles”, we find that spare parts for the gym equipment would be covered under Sub-heading 95069190 whereas spare parts for the outdoor playground equipment would be covered under Sub-heading 95069990.

16. However, on going through the list of spare parts being supplied by the applicant, we find that there is an item namely ‘bearings’ being supplied as spare parts for their product “outdoor gym equipment”. In this regard, we find that the spare part ‘bearings’ is not an item that can be specifically used only in outdoor gym equipment but can be used as spare parts in other equipment also. For these reasons, the said item cannot be classified under sub-heading 95 069190 and is required to be classified in the specific heading of the item in the Customs Tariff, if available. On going through the Customs Tariff, we find that there is a specific tariff entry for Bearings i.e. ball bearings & roller bearings under heading 8482 of Chapter 84 of the Customs Tariff Act, 1975 which reads as under:

8482 10 – Ball bearings

Adapter ball bearings (radial type) :

8482 10 11 – —: Not exceeding 50mm of bore diameter

8482 10 12 Of bore diameter exceeding 50 mm but not exceeding 100 mm

8482 10 13 Of bore diameter exceeding 100 mm

8482 10 20 – — Other ball bearing (radial type) of bore diameter not exceeding 50 mm

8482 10 30 – — Other ball bearing (radial type) of bore diameter exceeding 50 mm but not exceeding 100 mm

8482 10 40 – — Of bore diameter exceeding 100 mm

– — Thrust ball bearings

8482 10 51 Of bore diameter not exceeding 50 mm

8482 10 52 Of bore diameter exceeding 50 mm but not exceeding 100 mm

8482 10 53 Of bore diameter exceeding 100 mm

8482 10 90 – — Other

8482 20 – Tapered roller bearings, including cone and tapered roller assemblies:

– — Tapered roller bearings (radial type):

8482 20 11 – – —- Of bore diameter not exceeding 50 mm

8482 20 12 Of bore diameter exceeding 50 mm but not exceeding 100 mm

8482 20 13 – – —- Of bore diameter exceeding 100 mm

8482 20 90 – — Other

8482 30 00 – Spherical roller bearings

8482 40 00 – Needle roller bearings, including cage and needle roller assemblies

8482 50 00 – Other cylindrical roller bearings, including cage and roller assemblies

8482 80 00 – Other, including combined ball or roller bearings

– – Parts:

8482 91 — Balls, needles and rollers:

– — Balls:

8482 91 11 – – —- Of nickel alloys

8482 91 12 – – —- Of tungsten carbide

8482 91 13 – – —- Of special stainless steel

8482 91 14 – – —- Of high speed steel

8482 91 19 Other

8482 91 20 – — Needles

8482 91 30 – — Rollers

8482 99 00 – Other

The item namely “Bearings” would be classifiable under the sub-heading 95069190, only on account of being the spare parts of ‘Outdoor Gym Equipment’ in view of Sr.No.3 of Chapter Notes to Chapter 95. However, when there is a specific tariff entry available under heading 8482, the said item would be appropriately classifiable under Heading 8482 only, in view of Rule 3(a) of the General Rules for the Interpretation of the Schedule to the Customs Tariff Act, 1975 which reads that “the heading which provides the most specific description shall be preferred to headings providing a more general description. Hence, since Heading 8482 gives the more specific description of the said item, we find that the item “Bearings’ would be appropriately classifiable under Heading 8482 only. However, since proper details of the bearings have not been provided by the applicant alongwith their submission, it would not be possible for us to decide the appropriate HSN code for the said item. The applicant is advised to classify the said spare part in the appropriate tariff entry under heading 8482 as per the available specifications of the said item.

17. Now, since the classification of the products supplied by the applicant has been decided under the Customs Tariff Act, 1975, we proceed to examine the applicable GST rate for the supply of the products of the applicant as per the provisions of Notification No.09/2025-Central Tax (Rate) dated 17.09.2025. We, therefore, find it obligatory to refer to the said Notification. Relevant entries of Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025 read as under:

GOVERNMENT OF INDIA

MINISTRY OF FINANCE

(DEPARTMENT OF REVENUE)

NOTIFICATION

NO. 09/2025 Central Tax (Rate)

New Delhi, the 17th September, 2025.

18. From the above tables of Notification No.09/2025-Central Tax (Rate) dated 17.09.2025, we find that there are 2 entries pertaining to heading 9506 in the Notification i.e. Entry No.499 in Schedule-I and Entry No.619 in Schedule-II of the said Notification. On going through the same, we find that outdoor playground equipment supplied by the applicants such as slides, swings, see- saws, climbers, multi-activity play stations, being sports goods for children, would be aptly covered under Entry No.499 of Schedule-I of Notification No.09/2025-Central Tax Rate and liable to GST at 5% (2.5% CGST + 2.5% SGST). Consequently, spare parts for the said equipment would also be covered under the same Entry and would also be liable to GST at 5% (2.5% CGST + 2.5% SGST). However, the Outdoor gym equipment such as twisters, pull-up bars, cross-trainers, leg press etc. supplied by the applicant would be aptly covered under Entry No.619 of Schedule-II of Notification No.09/2025-Central Tax (Rate) and liable to GST at 18% (9% CGST + 9% SGST). Consequently, the spare parts of these equipment would also be covered under the said Entry and liable to GST at 18% (9% CGST + 9% SGST). However, as discussed in paras supra, the spare part namely “bearings” falling under the heading 8482 would be covered under the entry No.467 of Schedule-II of Notification No.09/2025- Central Tax (Rate) and liable to GST at 18% (9% CGST + 9% SGST).

19. In view of the above, we rule as under: –

Question- 1. What is the appropriate classification (HSN Code) under GST for:

Answer- 1. The appropriate classification (HSN Code) for the following equipment under GST is as under:

Question- 2. What is the applicable GST rate for supply of each of the above products in light of Notification No.09/2025-Central Tax (Rate) dated 17.09.2025?”

Answer- 2. The applicable GST rate for supply of each of the products in light of Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025 is as under:

“The rulings set forth in Answers 1 and 2 above, concerning the equipment parts manufactured by the applicant, are strictly subject to the validity and accuracy of the applicant’s submission.”