2, 2-Diphenyl-2-hydroxyacetic acid (benzilic acid)
Benzilic acid, 2,2-diphenyl-2-hydroxyacetic acid (Category 1B chemical)
HSN 2918 17 00 (Benzilic acid) is subject to dual primary-regulator control: import as a Category 1B chemical under the Chemical Weapons Convention Act and Rules is restricted to state parties to the CWC, with mandatory post-import notification to the National Authority CWC and DGFT under ITC (HS) policy condition 3 of Chapter 29. Where the substance falls within the Schedule to the Insecticides Act, 1968, registration and an import permit from the Central Insecticides Board and Registration Committee (CIB&RC) are additionally required under Rule 45 of the Insecticides Rules, 1971.
- Registration and import permit from CIB&RC
- Import certificate from NDPS authority
- Chapter 29 mandatory qualifiers from CBIC
Procedural directions for customs clearance are issued by: Directorate General of Foreign Trade, Central Board of Indirect Taxes and Customs.
- 1Verify that the exporting country is a state party to the Chemical Weapons Convention before placing the order. Within 30 days of import, notify the details of each consignment to the National Authority CWC (Cabinet Secretariat), Ministry of External Affairs (D&ISA), Department of Chemicals and Petrochemicals, and DGFT, and submit a copy of the bill of entry to DGFT within the same 30-day window.CWC Act and Rules · ITC (HS) policy condition 3 of Chapter 29 · Appendix-II of ITC (HS) Import Policy
- 2If the substance figures in the Schedule to the Insecticides Act, 1968, obtain registration and an import permit from the Secretariat of the Central Insecticides Board and Registration Committee. Route the consignment only through ports at which insecticides may be imported, as restricted under Rule 45 of the Insecticides Rules, 1971.Insecticides Act, 1968 · Rule 45 of the Insecticides Rules, 1971
- 3Ensure the import declaration includes the mandatory additional qualifiers prescribed under CBIC Circular 23/2023-Cus dated 30-09-2023 for commodities under Chapter 29, as stipulated in paragraphs 4.1 and 4.2, with effect from 15 October 2023. Where the substance is imported for medical or scientific purposes under the NDPS regime, obtain the import certificate under Rule 53 of the NDPS Rules, 1985 before filing the bill of entry.CBIC Circular 23/2023-Cus dated 30-09-2023 · Rule 53 of the NDPS Rules, 1985 · ITC (HS) policy condition 2 of Chapter 29
The most common error on this tariff line is treating the CWC Category 1B notification obligation as a pre-clearance formality when it is, in fact, a post-import compliance window: the 30-day notification to four separate authorities and the DGFT bill-of-entry submission are conditions attached to the import permission itself, and failure to meet them converts a lawful restricted import into a policy breach attracting DGFT enforcement. Additionally, importers frequently overlook that the insecticide-schedule check and the NDPS determination are independent gateways — both must be resolved at the classification stage, not retrospectively at the port.