2- Ethyl-2-(hydroxymethyl) propane-1,3-diol (trimethylolropane)
Trimethylolpropane, acyclic triol chemical intermediate
HSN 2905 41 00 (trimethylolpropane) is subject to Central Insecticides Board and Registration Committee (CIB&RC) registration and import permit requirements under the Insecticides Act, 1968, where the substance figures in the Schedule to that Act. Narcotic Drugs and Psychotropic Substances (NDPS) import-certificate controls under Chapter VII-A of the NDPS Rules, 1985, and mandatory Chapter 29 additional qualifiers under CBIC Circular 23/2023-Cus apply as additional clearance requirements.
- Registration certificate from CIB&RC
- Import permit from CIB&RC
- Chapter 29 qualifiers from CBIC
Procedural directions for customs clearance are issued by: Directorate General of Foreign Trade, Central Board of Indirect Taxes and Customs.
- 1Verify whether the specific formulation of trimethylolpropane being imported figures in the Schedule to the Insecticides Act, 1968. If it does, obtain registration and an import permit from the Secretariat of the Central Insecticides Board and Registration Committee before filing the bill of entry, and route the consignment only through ports permitted under Rule 45 of the Insecticides Rules, 1971.Insecticides Act, 1968 · Rule 45 of the Insecticides Rules, 1971 · ITC (HS) policy condition for Chapter 29
- 2If the substance is classified as an NDPS substance, obtain an import certificate under Rule 53 of the NDPS Rules, 1985 for medical or scientific purposes under Chapter VII-A of those Rules. Imports outside that category are governed by Appendix-I to the ITC (HS) Schedule per ITC (HS) policy condition 2 to Chapter 29.Chapter VII-A and Rule 53 of the NDPS Rules, 1985 · ITC (HS) policy condition 2 to Chapter 29
- 3Ensure the import declaration includes the mandatory additional qualifiers for Chapter 29 commodities as stipulated in paras 4.1 and 4.2 of CBIC Circular 23/2023-Cus. Additionally, where import of specified hazardous substances exceeds prescribed quantities, take out a public liability insurance policy under the provisions of the Public Liability Insurance Act, 1991 per S.O. 227(E) dated 24-03-1992.CBIC Circular 23/2023-Cus dated 30-09-2023 · S.O. 227(E) dated 24-03-1992
The critical error on this tariff line is assuming that because trimethylolpropane is primarily an industrial polyol intermediate, neither the CIB&RC pesticide schedule nor the NDPS overlay applies. Both regimes are triggered by the identity of the specific formulation, not by its principal commercial use — a formulation that figures in the Schedule to the Insecticides Act, 1968 requires CIB&RC registration regardless of the importer's end-use intent, and filing without that registration exposes the consignment to seizure under the Act.