PRE-BUDGET RECOMMENDATIONS 2012-2013 CEAMA Consumer Electronics and Appliances Manufacturers Association (CEAMA), an all India organization in the Consumer Electronics and Durable sector, looking after the common interest of the members, for sustainable growth in the sector. Been in existence for last 32 years. Presently, there are about 100 members. The membership spectrum comprises of both Domestic Corporates & MNCs, and includes large, medium and small-scale sectors. LG, Samsung, Videocon, Panasonic, Philips, Haier, Godrej, Whirlpool, Onida, Sharp, TCL, Onkyo etc. are our members. INTRODUCTION Consumer Durables manufacturing sector plays an important role in the economy of the Nation. Contributes more than 5.5% to the Index of Industrial Production. It is an employment intensive sector. For every one direct job that is created in this space, about three indirect jobs are created. This sector has been the engine of economic growth for Japan post Second World War, then Korea in 1980s, 1990s and now China & South-East Asian Countries in the 21st Century. Considering the low penetration level of the Consumer Electronics and Home Appliances in the country, this sector has immense growth potential. REDUCTION OF CUSTOMS DUTY ON PANELS FOR LCD & LED TVS It is expected that by next year almost 6 million LCD & LED TVs will be sold in the country and a major portion of this demand will be met through imports rather than local manufacturing. The reason for this is that there is zero duty on finished product of LCD & LED TV under the Free Trade Agreement with Thailand, whereas, the LCD panel which is the most important part of the LCD TV is imported at 5% basic customs duty. This is an incidence of inverted duty structure and to remedy the situation, the customs duty on inputs (LCD Panels) should not be more than that on the finished product (LCD TV). It is suggested that the Customs Duty on Panels for LCD & LED TVs should be brought down to 0%. This will give a boost to the Manufacturing of the LCD & LED TVs in India. It will also create a level playing field for all the Manufacturers for domestic market. It may create an opportunity for Export of TVs from India. IMPORT DUTY ON SET TOP BOX The recent ordinance on digitalization of TV will create huge demand for Set Top Boxes in the country and it is likely to touch 20 million pcs per annum. Most of the demand is likely to be met from imports as Indian manufacturers are facing huge disability factors. The disability factor for Indian manufacturer is in the form of 12.5% VAT which is paid by Indian manufacturers as cable and DTH operators do not provide ‘C’ Form since they are leasing out boxes. Cable and DTH operator do not pay any VAT when they import from China. We strongly suggest that the Customs Duty on Set Top Boxes should be increased to 10% from the present level of duty of 5% to encourage local manufacturing and create huge employment opportunities. SAD (SPECIAL ADDITIONAL DUTY) LEVIABLE ON IMPORTS TO BE ABOLISHED Manufacturers who are selling post imports items has to undergo cumbersome refund process for getting back Special Additional Duty (SAD) allowed vide Notfn. No. 102/97. The process of claiming refunds from customs is time consuming and take appx. 9 to 12 months for recovery. It is suggested that SAD levy should be removed both for trading and manufacturing items, as it does not generate revenue for the Govt. For Traders, SAD is exempted and for manufacturers CENVAT Credit available. More over this is adding to the transaction cost of Companies. Removal of SAD will not only result in cost saving for the Industry but also for the Government. This matter needs an URGENT resolution as the cash flows across the Industry are under pressure. R&D IMPORTS-CUSTOMS DUTY REDUCTION FROM 5% TO 0% Currently R&D units registered with the MOS can avail reduced Customs Duty of 5% + 3% Cess, on complying conditions laid down in Notfn. No. 51/96. We recommend that the Customs Duty for R&D items should be reduced to 0% to promote R&D in India, especially for Air-conditioning & Refrigeration and Electronics Industry, which has got big potential. This will invite more R&D set up in India in addition to technological advancement and more innovative Indian products. CUSTOMS DUTY REDUCTION ON IMPORT OF MAGNETRON FOR MANUFACTURE OF MICROWAVE In the Budget 2010-11, the Customs Duty on Magnetron has been reduced to 5%, under IGCR condition. Under this condition, the manufacturer who imports goods and then get it made through OEMs are not able to claim benefit of duty under IGCR and are liable to pay 10% Basic Customs Duty. As Magnetron is one of the most costly parts of Microwave, it is recommended that Customs duty on Magnetron should be reduced to 0%, without IGCR condition. This will result in competitive pricing of Microwaves. TRADE FACILITATIONS FOR IMPORTS AND EXPORTS Fund Allocation for Sea port development at Nhava Sheva, Pipav, Mundra, Chennai Advance Customs Clearance process for Imports and Exports to fasten the customs clearance process and free flow of trade. Customs Compliance to be shifted from current mode to Self compliance mode with stringent violations norms. 24 hr Customs clearance of Import and Exports, at all important ports in India. Faster Litigation Settlements through Fast track customs settlement commissions. Reduction in Airfreight percentage for calculation of Customs duty, currently it is 20% of FOB value, should be reduced to 6%. Online Customs Assistance to Trade on Import, Export, Duty Rate, Classification etc. INCREASE IN THE ABATEMENT RATE FOR MRP BASED EXCISE DUTY The products manufactured by our members are removed from the factory on the basis of MRP based Excise Duty in terms of provisions laid under Section 4A of Central Excise Act, 1944. The current level of the Abatement is as under:- Sr. No. Description of Goods Abatement under Central Excise 1. Monitor 20% 2. Air Conditioner 25% 3. LCD Television 30% 4. Plasma Television 30% 5. GSM Mobile Phones 35% 6. Refrigerator 35% The MRP based Excise Duty has actually increased the overall incidence of Excise Duty on the products related to Home Appliances sold in the aftermarket. According to cost calculations the overall Excise burden has increased due to MRP Based Excise Assessment. This is due to the fact that the abatement rate is not adequate to cover all the taxes and distribution margins involved in the long Home Appliances supply chain. However, if the Government decides to continue the levy in the present form, then the abatement has to be raised to the level of 45%. Since the discount to be passed on to buyers is very high, the manufacturers of Home Appliances products are forced to bear the duty incidence on account of stiff competition. To save the Home Appliances manufacturers from significant losses, it is suggested that the MRP based assessment for Home Appliance products should be increased to at least 45% from the current level. REDUCTION OF CST RATE CST rate was meant to reduce each year in order to pave way for GST. However, for the last 3 years, the rate of CST has been constant at 2%. Since, CST is not creditable; it is a cost for manufacturers leading to increase in prices. It is strongly recommended that the CST rate should be reduced from 2% to 1%. It is also suggested that the CST Rate without Statutory form should be fixed at lower from highest to the average i.e. 10% for registered dealers. CONCLUSION If our recommendations are accepted, it will result in growth of demand in our sector. Manufacturing will get a boost and will generate more revenue for both Union as well as State Governments.