Hydrogen chloride (hydrochloric acid)

Hydrogen chloride and hydrochloric acid

CBIC CLEARANCE

HSN 2806 10 00 (Hydrogen chloride / hydrochloric acid) is subject to mandatory additional qualifier declarations in import filings administered by the Central Board of Indirect Taxes and Customs (CBIC) under CBIC Circular 23/2023-Cus dated 30-09-2023, effective 15 October 2023. Imports of this specified hazardous substance exceeding notified threshold quantities additionally require a Public Liability Insurance policy under S.O. 227(E) dated 24-03-1992 issued by the Ministry of Environment and Forests.

What this is

HSN code

2806 10 00

Chapter

28 · Inorganic chemicals; organic or inorganic compounds of precious metals

Primary regulator

CBIC · CBIC Circular 23/2023-Cus; Public Liability Insurance Act, 1991

Customs documentation

Chapter 28 qualifiers from CBIC
Insurance policy from insurer
Hazardous-substance declaration to CBIC

Compliance steps

1
Include all 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 at the bill-of-entry stage with effect from 15 October 2023 and non-compliance triggers re-assessment or detention of the consignment.
CBIC Circular 23/2023-Cus dated 30-09-2023, para 4.1 and 4.2
2
Where the quantity of hydrogen chloride imported exceeds the threshold specified under S.O. 227(E) dated 24-03-1992, obtain a Public Liability Insurance policy covering third-party liability arising from handling of the hazardous substance before filing the bill of entry.
Public Liability Insurance Act, 1991 · S.O. 227(E) dated 24-03-1992, Ministry of Environment and Forests

A word of counsel

The most common error on this tariff line is filing the bill of entry without the Chapter 28 mandatory qualifiers required under CBIC Circular 23/2023-Cus — a deficiency that customs systems flag automatically post-15 October 2023, resulting in consignment detention and demurrage while declarations are re-filed. Separately, importers frequently overlook the Public Liability Insurance obligation for threshold-exceeding quantities; the PLI policy must be in place before arrival, not arranged reactively at the port.

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Frequently asked

Does HSN 2806 10 00 require BIS certification?

No, hydrogen chloride and hydrochloric acid are not subject to any BIS Quality Control Order. Import compliance for this tariff line is governed by CBIC Circular 23/2023-Cus mandatory qualifier requirements and, where applicable, the Public Liability Insurance Act, 1991 for threshold-quantity hazardous substance imports.

What are the mandatory additional qualifiers required under CBIC Circular 23/2023-Cus for Chapter 28 imports?

Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023 prescribe the qualifier fields to be populated in import declarations for commodities under Chapters 28, 29, 32, 39 and CTH 3808; the specific field requirements must be confirmed against the circular's Annexure.

Does the Public Liability Insurance requirement apply to every import of hydrochloric acid?

No — the insurance obligation under S.O. 227(E) dated 24-03-1992 applies only where the imported quantity of the specified hazardous substance exceeds the threshold quantities notified under the Public Liability Insurance Act, 1991.

Last verified against gazette notifications: 2026-05-16. Source: CBIC / Indian Customs CUSDATA.