Thionyl chloride
Thionyl chloride, halide of non-metals (Category 1C chemical)
HSN 2812 17 00 (Thionyl chloride) is subject to the Chemical Weapons Convention (CWC) Act and Rules administered by the Directorate General of Foreign Trade (DGFT) as a Category 1C scheduled chemical under Appendix II of the ITC (HS) import policy, with import permitted from both State Parties and Non-State Parties to the CWC subject to post-import notification. Central Board of Indirect Taxes and Customs (CBIC) Circular 23/2023-Cus mandatory additional qualifiers in Chapter 28 import declarations apply as a concurrent customs overlay.
- Bill of entry copy to DGFT
- Chapter 28 qualifiers from CBIC
- Post-import notification to National Authority
- 1Verify that the supplier is located in a State Party or Non-State Party to the Chemical Weapons Convention — both are permissible origin sources for Category 1C chemicals under Appendix II of the ITC (HS) import policy. Record the origin classification in the import file before the bill of entry is filed.Appendix II of ITC (HS) Import Policy · CWC Act and Rules · Policy condition 2 of Chapter 28
- 2Within 30 days of import, notify the consignment details to: the National Authority, Chemical Weapons Convention, Cabinet Secretariat; Ministry of External Affairs (D & ISA); Department of Chemicals and Petrochemicals; and DGFT. Submit a copy of the bill of entry to DGFT within the same 30-day window.Appendix II of ITC (HS) Import Policy · Policy condition 2 of Chapter 28 · CWC Act and Rules
- 3Comply with CBIC Circular 23/2023-Cus dated 30-09-2023 by including mandatory additional qualifiers in the import declaration for Chapter 28 commodities as stipulated in paragraphs 4.1 and 4.2, effective 15 October 2023. Declarations missing the required Chapter 28 qualifiers will be held deficient at the bill of entry stage.CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2
The most common error on this tariff line is treating the CWC notification obligation as a pre-clearance matter and overlooking that it is a mandatory post-import reporting requirement with a strict 30-day window. Failure to notify all four designated authorities — National Authority CWC, Ministry of External Affairs (D & ISA), Department of Chemicals and Petrochemicals, and DGFT — and to submit the bill of entry copy within 30 days constitutes a policy-condition breach under Chapter 28, which attracts DGFT enforcement action independent of whether the goods have already been cleared from customs.