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Polyphosphoric acids

Polyphosphoric acids for industrial use

BIS QCO APPLICABLE · ISI MARK SCHEME · IS 17439

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.

What this is
HSN code
2809 20 20
Chapter
28 · Inorganic chemicals; organic or inorganic compounds of precious metals
BIS QCO
Applicable · ISI Mark Scheme · CM/L required
Indian Standard
IS 17439:2020 · effective 22-12-2022
Applicable Partner Government Agencies
BISBIS·Bureau of Indian Standards

Procedural directions for customs clearance are issued by: Central Board of Indirect Taxes and Customs.

Compliance steps
  1. 1
    Source 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
  2. 2
    Ensure 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
  3. 3
    Obtain 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
  4. 4
    Declare 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
  5. 5
    Quote 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
A word of counsel

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.

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Frequently asked
Does HSN 2809 20 20 require BIS certification?
Yes. Conformity to IS 17439:2020 is mandatory under the ISI Mark Scheme with effect from 22 December 2022; import is permitted only from manufacturers holding a current BIS CM/L licence covering the relevant product scope and manufacturing facility.
Are additional import declaration qualifiers required for polyphosphoric acid under Chapter 28?
Yes. CBIC Circular 23/2023-Cus dated 30 September 2023 mandates additional qualifiers in import declarations for Chapter 28 commodities with effect from 15 October 2023. This is a customs-clearance overlay separate from the BIS QCO obligation.
What is the operative enforcement date for the Polyphosphoric Acid QCO — 24 December 2021 or 22 December 2022?
The gazette publication date of the Polyphosphoric Acid (Quality Control) Order, 2021 is 24 December 2021 per S.O. 5388(E); the operative ISI-marking enforcement date is 22 December 2022 as amended by S.O. 2226(E) dated 13 May 2022.
Does a single CM/L licence cover all grades and facilities of polyphosphoric acid from the same manufacturer?
No. A CM/L licence is scope-specific by product grade and manufacturing facility; material from a facility or specification outside the licensed scope is not covered, and customs detains the consignment on a scope mismatch.
Last verified against gazette notifications: 2026-05-16. Source: BIS / CBIC / Indian Customs CUSDATA.
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