Polyphosphoric acids
Polyphosphoric acids for industrial use
HSN 2809 20 20 (polyphosphoric acids) is covered by a Bureau of Indian Standards Quality Control Order. Conformity to IS 17439:2020 is mandatory under the ISI Mark Scheme with effect from 22 December 2022, by virtue of the Polyphosphoric Acid (Quality Control) Order, 2021. Central Board of Indirect Taxes and Customs mandatory additional-qualifier requirements for Chapter 28 commodities apply as a separate customs-clearance overlay.
Procedural directions for customs clearance are issued by: Central Board of Indirect Taxes and Customs.
- 1Source only from a Bureau of Indian Standards CM/L-licensed manufacturer holding a current licence against IS 17439:2020. Verify the supplier's CM/L number, licensed product scope, and manufacturing facility address on the BIS online register before placing the purchase order.Polyphosphoric Acid (Quality Control) Order, 2021 · S.O. 5388(E) dated 24-12-2021 · S.O. 2226(E) dated 13-05-2022
- 2Ensure each consignment batch bears the ISI mark and the supplier's CM/L number under licence per Scheme-II of Schedule-II to the BIS (Conformity Assessment) Regulations, 2018. Marking must appear on the product container or label, not on outer packaging alone.Scheme-II of Schedule-II to the BIS (Conformity Assessment) Regulations, 2018 · Polyphosphoric Acid (Quality Control) Order, 2021
- 3Obtain and retain the manufacturer's test certificates confirming conformity to IS 17439:2020 parameters — total phosphorus pentoxide content, average chain length, viscosity, colour, iron content, and moisture — for each shipment. These records support customs examination and post-clearance audit.IS 17439:2020 · Polyphosphoric Acid (Quality Control) Order, 2021 · S.O. 5388(E) dated 24-12-2021
- 4Declare the mandatory additional qualifiers for Chapter 28 commodities in the import declaration, as specified in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. This requirement applies with effect from 15 October 2023 and is independent of the BIS QCO obligation.CBIC Circular 23/2023-Cus dated 30-09-2023
- 5Quote the supplier's BIS CM/L number on the bill of entry. Customs verifies the CM/L against the BIS register in real time; an absent, expired, or product-scope-mismatched licence triggers consignment detention, demurrage, and ground rent liability.Polyphosphoric Acid (Quality Control) Order, 2021 · BIS Act, 2016 · Customs Act, 1962
The single most common error on this tariff line is relying on the gazette publication date of S.O. 5388(E) — 24 December 2021 — as the BIS QCO effective date, when the actual enforcement date requiring ISI marking is 22 December 2022 per S.O. 2226(E). Consignments shipped before confirming the supplier's CM/L was valid as of the 22 December 2022 operative date, or after that date from an unlicensed manufacturer, face detention regardless of the product's physical conformity to IS 17439:2020 parameters.