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HomeHSNChapter 28HSN 2801 20 00

Iodine

Iodine, halogens for pharmaceutical and chemical use

CBIC CLEARANCE

HSN 2801 20 00 (Iodine) attracts Central Board of Indirect Taxes and Customs (CBIC) mandatory Chapter 28 qualifier declarations under CBIC Circular 23/2023-Cus dated 30-09-2023, effective 15 October 2023. Where iodine is imported as a drug or pharmaceutical input, five additional documents — including a registration certificate and import licence for drugs — must be uploaded in e-Sanchit before customs out-of-charge.

What this is
HSN code
2801 20 00
Chapter
28 · Inorganic chemicals; organic or inorganic compounds of precious metals
Primary regulator
CBIC · CBIC Circular 23/2023-Cus dated 30-09-2023 (Chapter 28 mandatory qualifiers)
Customs documentation
  • Certificate of analysis from supplier
  • Registration certificate from CDSCO
  • Import licence for drugs from CDSCO
Compliance steps
  1. 1
    Include the mandatory additional qualifiers in the import declaration for Chapter 28 commodities as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers are compulsory for all bills of entry filed on or after 15 October 2023 and non-compliance renders the bill liable to amendment or detention.
    CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2
  2. 2
    Where iodine is classified as a drug or pharmaceutical input, upload all five mandatory documents in e-Sanchit before filing the bill of entry: Certificate of Analysis — Drug (document code 0010dc), Batch Release Certificate (0030dc), Label of Consignment (0110dc), Registration Certificate — Drugs (101dc1), and Import Licence for Drugs (9111dc). Out-of-charge will not be granted until all five are verified in e-Sanchit.
    CBIC Circular 23/2023-Cus dated 30-09-2023 · e-Sanchit document codes 0010dc, 0030dc, 0110dc, 101dc1, 9111dc
A word of counsel

The most common error on this tariff line is assuming that iodine imported as a chemical intermediate requires only the Chapter 28 qualifier declaration, while overlooking that any consignment characterised — or reclassifiable — as a drug input triggers the full five-document pharmaceutical upload regime. Customs officers conducting PGA-facilitated bill verification will check e-Sanchit for all five drug-related document codes; a missing Registration Certificate (101dc1) or Import Licence (9111dc) will cause out-of-charge to be withheld, accruing demurrage and ground rent.

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Frequently asked
Does HSN 2801 20 00 require BIS certification?
No, iodine under this tariff line is not covered by any BIS Quality Control Order. Compliance obligations are governed by CBIC Circular 23/2023-Cus mandatory qualifier requirements for Chapter 28 import declarations, and, where the product is a drug or pharmaceutical input, by the documentary regime administered under the Drugs and Cosmetics Act, 1940.
What are the mandatory document codes for pharmaceutical-grade iodine and where must they be submitted?
Five documents must be uploaded in e-Sanchit: Certificate of Analysis — Drug (0010dc), Batch Release Certificate (0030dc), Label of Consignment (0110dc), Registration Certificate — Drugs (101dc1), and Import Licence for Drugs (9111dc); out-of-charge is withheld until all five are verified.
Does the Chapter 28 qualifier obligation apply to every import of iodine, irrespective of end use?
Yes. The mandatory additional qualifiers under paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus apply to all import declarations for Chapter 28 commodities with effect from 15 October 2023, regardless of whether the iodine is destined for pharmaceutical, industrial, or any other end use.
Last verified against gazette notifications: 2026-05-16. Source: CBIC / Indian Customs CUSDATA.
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