GST Classification of “Turmeric Extract / Curcuma Elixir” as Nutraceutical under HSN 2106

1. Background of the Advance Ruling

The ruling in In re CSM Universe Pvt Ltd (GST AAR Kerala) concerns the GST classification and tax rate applicable to a product marketed as “Turmeric Extract / Curcuma Elixir”.

M/s CSM Universe Private Limited, a company incorporated under the Companies Act 2013 and registered under GST with GSTIN 32AALCC2042C1ZC, approached the Kerala Authority for Advance Ruling seeking clarity under Section 97 of the Central Goods and Services Tax Act 2017 and the corresponding provisions of the Kerala Goods and Services Tax Act 2017.

The assessee manufactures and supplies a turmeric-based liquid preparation proposed to be sold as a nutraceutical wellness supplement. Two key questions were placed before the Authority:

  1. The correct GST classification and rate applicable to “Turmeric Extract / Curcuma Elixir”; and
  2. Whether the MRP of Rs. 4,990 (being less than Rs. 5,000) has any effect on the applicable GST rate.

The Authority examined the manufacturing process, product composition, FSSAI licensing, lab test results, and the marketing claims before arriving at its conclusion.

Note: References to the CGST Act, rules and notifications in the ruling are to be read as including the parallel provisions of the KGST law.

2. Product Description and Manufacturing Process

2.1 Initial description by the assessee

In the original application, the assessee described “Turmeric Extract / Curcuma Elixir” as a liquid product derived from turmeric rhizomes (Curcuma longa). The process was stated to involve:

  • Procuring turmeric rhizomes,
  • Cleaning and drying, and
  • Extraction through steam distillation to retain essential curcuminoid content.

The assessee emphasised that:

  • Only natural turmeric extract is used,
  • The product has high moisture content,
  • No synthetic preservatives or additives are added, and
  • It is intended as a nutraceutical wellness supplement for:
    • Anti-inflammatory support,
    • Antioxidant effect,
    • Immune support,
    • Joint health,
    • Liver support, and
    • Overall well-being.

On this basis, the assessee initially claimed that the product is medicinal in nature and should be treated as a medicament taxable at 5% GST, largely relying on turmeric’s well-known medicinal and health-protective properties.

2.2 Subsequent clarification on process – Arkakalpana method

Later, by letter dated 20.02.2026, the assessee refined its explanation of the manufacturing process. The updated description stated that:

  • Fresh turmeric rhizomes are sourced from approved vendors.
  • The rhizomes are thoroughly cleaned with water.
  • The cleaned turmeric is cut into pieces and mixed with water.
  • This mixture is heated in a closed stainless-steel vessel under hygienic conditions.
  • Turmeric and water are boiled together so that the natural constituents are transferred into the aqueous medium.
  • This process follows the traditional Ayurvedic water-based method “Arkakalpana”.
  • The resultant liquid is collected, filtered in a controlled hygienic environment, and filled directly into sealed retail bottles.

Critical points highlighted by the assessee:

  • No essential oil is separated or recovered at any stage.
  • No fragrance, flavour, or aromatic component is extracted or sold separately.
  • No preservatives, artificial colours, flavours, or chemicals are added.
  • The final product is labelled with dosage instructions and is supplied for direct human consumption.

3. Regulatory and Laboratory Evidence Produced

3.1 FSSAI licensing and product categorisation

The assessee submitted that the product is manufactured and sold under a valid licence from the Food Safety and Standards Authority of India (FSSAI). Salient features of the licence:

  • Business type: “Manufacturer – Food / Health Supplements and Nutraceuticals”.
  • Classified under:
    • Food Category 13 – Foodstuffs intended for particular nutritional uses,
    • Sub-category 13.6 – Food Supplements.
  • Product description: “Nutraceutical – Curcuma Longa Extract (Without Additives) – Liquid”.

The assessee also clarified that it:

  • Complies with all applicable food safety, storage, labelling and sale norms, and
  • Does not hold any manufacturing licence for essential oils, perfumes, fragrances, flavouring agents or cosmetics.

3.2 Laboratory test results and composition

The assessee produced reports from NABL-accredited laboratories, including:

  • Pesticide residue, chemical and nutritional analysis report;
  • Microbiological test report.

Key findings as stated in the application:

  • Compliance with microbiological safety norms;
  • Absence of heavy metals;
  • No synthetic preservatives, added colours, steroids or prohibited substances detected;
  • Presence of active turmeric constituents;
  • Moisture content approximately 99.91%, indicating a predominantly water-based liquid.

In addition, the chemical examination report dated 20.11.2025 examined by the Authority recorded that:

  • The product is an aqueous distillate obtained through steam distillation;
  • It contains only a minuscule trace of curcumin;
  • About 99.9% of the product comprises moisture/water.