Butylated hydroxyanisole (BHA)
Butylated hydroxyanisole (BHA), ether-phenol antioxidant
HSN 2909 50 50 (Butylated hydroxyanisole, BHA) is subject to registration and import permit requirements of the Central Insecticides Board and Registration Committee (CIB&RC) under the Insecticides Act, 1968 and Rule 45 of the Insecticides Rules, 1971, where BHA figures in the Schedule to that Act. Narcotic Drugs and Psychotropic Substances (NDPS) Rules, 1985 controls and ITC (HS) policy condition 2 of Chapter 29 administered by the Directorate General of Foreign Trade (DGFT) apply as additional overlays, and mandatory Chapter 29 qualifiers under CBIC Circular 23/2023-Cus are required at the bill-of-entry stage.
- 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.
- 1Confirm whether BHA as imported falls within the Schedule to the Insecticides Act, 1968. If scheduled, obtain registration and an import permit from the Secretariat of the Central Insecticides Board and Registration Committee before shipment; import is also restricted to notified places under Rule 45 of the Insecticides Rules, 1971.Insecticides Act, 1968 · Rule 45 of the Insecticides Rules, 1971 · ITC (HS) policy condition 2 of Chapter 29
- 2Upload all mandatory documents in e-Sanchit before filing the bill of entry: Certificate of Analysis — Drug (document code 0010dc), Batch Release Certificate (0030dc), Label of Consignment (0110dc), Registration Certificate — Drugs (101dc1), and Import Licence for Drugs (9111dc). The proper officer will verify these uploads before granting out-of-charge.CBIC e-Sanchit document codes 0010dc, 0030dc, 0110dc, 101dc1, 9111dc
- 3Declare mandatory additional qualifiers in the import declaration as required under paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus for commodities under Chapter 29, with effect from 15 October 2023. Where BHA is imported as an NDPS-scheduled substance for medical or scientific purposes, obtain an import certificate under Rule 53 of the NDPS Rules, 1985 as per Chapter VII-A of those Rules.CBIC Circular 23/2023-Cus dated 30-09-2023 · Rule 53 of the NDPS Rules, 1985 · Appendix-I to ITC (HS) Schedule
The most frequent error on this tariff line is assuming that CIB&RC clearance is automatic because BHA is primarily a food antioxidant rather than a pesticidal active: if the imported grade or formulation appears in the Schedule to the Insecticides Act, 1968, CIB&RC registration and permit are mandatory regardless of the end-use declared, and import through an un-notified port under Rule 45 constitutes a separate Insecticides Rules violation. Additionally, importers overlook the Public Liability Insurance requirement under S.O. 227(E) dated 24-03-1992 when the consignment exceeds the specified threshold quantity of a scheduled hazardous substance.