December 21, 2020

Ref. No.: IWM/114/2020

Mr. Abdul Razak Dawood

Adviser to PM
Ministry of Commerce & Industry
Government of Pakistan

Subject: Request for revision in Duty Structure

Dear Sir,

Interwood Mobel Private Limited is leading furniture manufacturer with ISO certification in Pakistan.
We are 100% compliant of all the rules & regulations of the country, we have contributed towards
Government exchanger approximately Rs.300 Million through various taxes in last one year.  We believe
on innovation which is one of our core values. We always search for new technologies to enhance the
quality of our production lines. We are also among those industrial units which have not laid off any
worker during this pandemic crisis and also trying to fulfill all our financial and social obligations.

Recently, Government has imposed regulatory duty and made some changes in valuation ruling on
certain luxurious items to bring the import bill under control and promote the local industry.

In this regard government have imposed regulatory duty up to 45% on furniture items falling under PCT
94.03. It is proposed to impose regulatory duty on following PCT as well, to achieve the target of
reducing the imports of Finished luxury items.

Existing Duty Proposed Duty

Structure Structure
CD ACD RD CD ACD RD
Chapter 44 Wood and Articles of Wood
PCT 44.18 Builders’ joinery and carpentry of 20% 7% - 20% 7% 45%
wood, including cellular wood panels,
assembled flooring panels, shingles
and shakes. (PCT 4418.1000
Windows and PCT 4418.2000 Doors)
On the other hand, certain necessary inputs required for the production of furniture items are levied with
regulatory duty. These items are also not available locally, in order to promote local industry, it is
proposed to remove regulatory duty as well as custom duty on items as follows.

Existing Duty Proposed Duty

Structure Structure
CD ACD RD CD AC RD Reason
D
Chapter Paints and Varnishes
32
PCT 32.08 Paints and varnishes 20% 7% 10% 10% - - UV based
(including enamels and material not
lacquers) based on available
synthetic polymers or locally,
chemically modified additionally,
natural polymers, locally available
dispersed or dissolved in material is not
a non-aqueous medium; compatible with
solutions as defined in machine-based
Note 4 to this chapter. production
PCT 32.09 Paints and varnishes 20% 7% 10% 10% - - hence accounts
(including enamels and for extra
lacquers) based on wastage.
synthetic polymers or
chemically modified
natural polymers,
dispersed or dissolved in
an aqueous medium.
PCT 32.12 Pigments (including 20% 7% - 10% - -
metallic powders and
flakes) dispersed in non-
aqueous media, in liquid
or paste form, of a kind
used in the manufacture
of paints (including
enamels); stamping
foils; dyes and other
coloring matter put up in
forms or packing for
retail sale. (PCT
3212.9090 Other)
Chapter Miscellaneous
38 Chemical Products
PCT 38.14 Organic composite 20% 7% - 10% - -
solvents and thinners,
not elsewhere specified
 Existing Duty Proposed Duty
Structure Structure
CD ACD RD CD AC RD Reason
D
or included; prepared
paint and varnish
remover.
Chapter Wood and Articles of
44 Wood
PCT 44.08 Sheets for veneering 3% 2% - 0%- - - Basic raw
(including those material for
obtained by slicing furniture
laminated wood), for industry, not
plywood or for similar available
laminated wood and locally.
other wood, sawn
lengthwise, sliced or
peeled, whether or not
planed, sanded spliced
or end-jointed, of a
thickness not exceeding
6mm.
PCT 44.10 Particle board, oriented 16% 4% - 8% - - Locally
strand board (OSB) and produced
similar board (for material
example wafer board) of contains
wood or other ligneous hazardous flame
materials, whether or not of
agglomerated with resins formaldehyde,
or other organic binding whereas
substances. imported
PCT 44.11 Fiberboard of wood or 11% 2% 5% 5% - - material uses
other ligneous materials, E1, E2 glue.
whether or not bonded Moreover,
with resins or other locally available
organic substances. material varies
PCT 44.12 Plywood, veneered 20% 7% - 10% - - in size,
panels and similar resultantly not
laminated wood. suitable for
industrial
manufacturing.
Chapter
55
PCT 55.12 Woven fabrics of 16% 4% 2.5% 10% - -
synthetic staple fibres,
containing 85 % or more
by weight of synthetic
 Existing Duty Proposed Duty
Structure Structure
CD ACD RD CD AC RD Reason
D
staple fibres.
,
 Chapter 83

PCT 83.02 Base metal mountings, 20% 7% 5% 10% - - Hardware not

fittings and similar available locally.
articles suitable for
furniture, doors,
staircases, window,
blinds, coachwork,
saddlery, trunks, chests,
caskets or the like; base
metal hat-racks, hat-pegs,
brackets and similar
fixtures; castors with
mountings of base metal;
automatic door closers of
base metal. (PCT
8302.4200 Other suitable
for furniture)

Chapter 84
PCT 84.14 Air or vacuum pumps, air 20% 7% - 10% - -
or other gas compressors
and fans; ventilating or
recycling hoods
incorporating a fan,
whether or not fitted with
filters.
(PCT 8414.6000 Hoods
having a maximum
horizontal side not
exceeding 120cm)

Further to above it is pertinent to mention that the Valuation rulings of different items like specialized
imported fabric through valuation ruling No 1454/2020 dated 24 th June 2020 have been increased
significantly, resulting in higher amounts of duties payable. Values determined in these rulings are much
exaggerated and higher than the actual import value of these specialized Fabrics not available locally.

Looking forward to have a positive response from your side on all the requests.

Very truly yours,

Omar Farooq
Chief Executive Officer | Interwood Mobel Pvt. Ltd.
Independent Director |SME Bank
Regional Finance Officer |YPO (Middle East / North Africa)