Carbonyl dichloride (phosgene)

Carbonyl dichloride (phosgene), Category 1C CWC chemical

DGFT CLEARANCE · CBIC CLEARANCE

HSN 2812 11 00 (Carbonyl dichloride / phosgene) is governed by the Directorate General of Foreign Trade (DGFT) under the ITC (HS) import policy administered pursuant to the Chemical Weapons Convention Act and Rules, with post-import notification to the National Authority, Chemical Weapons Convention (CWC) and allied ministries mandatory within 30 days of each consignment. The Central Board of Indirect Taxes and Customs (CBIC) Circular 23/2023-Cus imposes mandatory additional qualifiers in the import declaration, and Public Liability Insurance under S.O. 227(E) dated 24-03-1992 applies where import quantities exceed prescribed thresholds.

What this is

HSN code

2812 11 00

Chapter

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

Primary regulator

DGFT · ITC (HS) Appendix-II CWC policy condition 2, Chapter 28

Customs documentation

ITC (HS) policy declaration from DGFT
Chapter 28 qualifiers from CBIC
Bill of entry copy for DGFT submission

Compliance steps

1
Verify the exporting country's status as a State Party or Non-State Party to the Chemical Weapons Convention before filing the bill of entry — import of carbonyl dichloride (phosgene) as a Category 1C chemical is permitted from both categories, but remains subject to ITC (HS) Appendix-II policy condition 2 of Chapter 28. File the bill of entry with all mandatory Chapter 28 additional qualifiers as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus, effective 15 October 2023.
ITC (HS) Appendix-II, policy condition 2 of Chapter 28 · CBIC Circular 23/2023-Cus dated 30-09-2023
2
Within 30 days of each import, submit written notification of consignment details to: the National Authority, Chemical Weapons Convention (Cabinet Secretariat); Ministry of External Affairs (D&ISA); Department of Chemicals and Petrochemicals; and DGFT. Simultaneously submit a copy of the bill of entry to DGFT. This 30-day post-import notification is a standing obligation for every consignment, not a one-time registration.
CWC Act and Rules · ITC (HS) Appendix-II, policy condition 2 of Chapter 28
3
Where the import quantity of phosgene exceeds the prescribed threshold under the Public Liability Insurance Act, 1991, the owner must take out the requisite insurance policy before handling or storing the consignment. Non-compliance attracts liability under the PLI Act, 1991.
S.O. 227(E) dated 24-03-1992 · Public Liability Insurance Act, 1991

A word of counsel

The single most common error on this tariff line is treating the CWC post-import notification as an administrative formality that can be filed whenever convenient. The 30-day window is a hard statutory deadline tied to each individual consignment — a missed or late notification constitutes a breach of policy condition 2 of Chapter 28 and exposes the importer to DGFT enforcement action independent of customs clearance. The bill of entry copy submitted to DGFT must correspond exactly to the customs-cleared document; discrepancies between the declared import declaration and the post-import submission have triggered scrutiny under the CWC Rules.

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Frequently asked

Does HSN 2812 11 00 require BIS certification?

No. Carbonyl dichloride (phosgene) is not covered by any BIS Quality Control Order. Import is governed by DGFT under the ITC (HS) Appendix-II CWC policy regime and the Chemical Weapons Convention Act and Rules, with post-import notification obligations and CBIC mandatory-qualifier requirements under Circular 23/2023-Cus.

Is the Chapter 28 mandatory qualifier requirement in the import declaration new, and which fields are affected?

Yes. CBIC Circular 23/2023-Cus dated 30-09-2023 made additional qualifiers mandatory for import declarations under Chapter 28 with effect from 15 October 2023; the specific fields are set out in paragraphs 4.1 and 4.2 of that Circular, and non-compliant declarations are liable to be treated as misdeclarations.

Does the post-import CWC notification obligation apply to imports from Non-State Parties to the CWC?

Yes. ITC (HS) Appendix-II policy condition 2 of Chapter 28 applies to imports from both State Parties and Non-State Parties to the CWC; the 30-day notification obligation to the National Authority, MEA, Department of Chemicals and Petrochemicals, and DGFT is mandatory in both cases.

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