Epsilon acid (1-naphthylamine-3,8-disulphonic acid)
Epsilon acid, naphthylamine disulphonic acid derivative
HSN 2921 45 23 (Epsilon acid) is subject to Central Insecticides Board and Registration Committee (CIB&RC) registration and import permit under the Insecticides Act, 1968, where the substance appears in its Schedule, with import restricted to notified places under Rule 45 of the Insecticides Rules, 1971. Narcotic Drugs and Psychotropic Substances (NDPS) conditions under Chapter VII-A of the NDPS Rules, 1985 apply where the substance is classified under that regime, and the Directorate General of Foreign Trade (DGFT) Restricted-import policy covers Chemical Weapons Convention (CWC) schedule overlays. Central Board of Indirect Taxes and Customs (CBIC) Circular 23/2023-Cus mandates mandatory additional qualifiers in the import declaration from 15 October 2023.
- 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 the substance falls within the Schedule to the Insecticides Act, 1968. If it does, obtain registration and an import permit from the secretariat of CIB&RC before dispatch, and route the consignment only through places notified under Rule 45 of the Insecticides Rules, 1971. Upload document codes 101dc1 and 9111dc in e-Sanchit before filing the bill of entry.Insecticides Act, 1968 · Rule 45 of the Insecticides Rules, 1971 · ITC (HS) policy condition for Chapter 29
- 2Where the consignment attracts the NDPS regime, obtain an import certificate under Rule 53 of the NDPS Rules, 1985 for medical or scientific purposes before shipment. Imports outside the medical-and-scientific 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
- 3Comply with CBIC Circular 23/2023-Cus dated 30-09-2023 by furnishing mandatory additional qualifiers in the import declaration for Chapter 29 commodities, effective 15 October 2023 as stipulated in paragraphs 4.1 and 4.2 of that Circular. Upload the Certificate of Analysis (document code 0010dc), Batch Release Certificate (0030dc), and Label of Consignment (0110dc) in e-Sanchit before out-of-charge.CBIC Circular 23/2023-Cus dated 30-09-2023, paras 4.1 and 4.2
The most frequent error on this tariff line is treating CIB&RC registration as optional on the assumption that Epsilon acid is primarily a dye intermediate rather than a pesticide precursor. Whether the substance is Schedule-listed under the Insecticides Act, 1968 is a fact-specific determination; arriving at a non-notified port or without a current CIB&RC import permit — even for a consignment ultimately destined for dye manufacture — exposes the importer to seizure and prosecution under the Insecticides Act. The CWC Appendix II Category IA and IB restrictions on related nitrogen compounds in the same CTI should also be checked against the specific molecular identity before the purchase order is placed.