Lecithins
Lecithins and other phosphoaminolipids (food-grade, technical)
HSN 2923 20 10 (Lecithins) is subject to Food Safety and Standards Authority of India (FSSAI) Import Licence requirements under the Food Safety and Standards Act, 2006 where the lecithin is food-grade, and to Central Insecticides Board and Registration Committee (CIB&RC) registration and import permit under the Insecticides Act, 1968 where the substance falls within the Schedule to that Act. Narcotic Drugs and Psychotropic Substances (NDPS) conditions under Chapter VII-A of the NDPS Rules, 1985, ITC (HS) policy condition 2 of Chapter 29, and mandatory Chapter 29 qualifiers under CBIC Circular 23/2023-Cus apply as additional clearance requirements.
- Import Licence from FSSAI
- Registration certificate 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.
- 1Determine the end-use category of the lecithin consignment before filing the bill of entry. For food-grade lecithins, obtain the FSSAI Import Licence (document code 911001) and ensure the Specimen Copy of Label (document code 0110FS) is uploaded in e-Sanchit. For lecithins falling within the Schedule to the Insecticides Act, 1968, obtain registration and an import permit from the Secretariat of CIB&RC, noting that places of import for insecticides are restricted under Rule 45 of the Insecticides Rules, 1971.FSSAI Import Licence · document code 911001 · CIB&RC registration and permit · Rule 45 of the Insecticides Rules, 1971
- 2Upload all mandatory e-Sanchit documents before customs out-of-charge: Certificate of Analysis — Drug (0010dc), Batch Release Certificate (0030dc), Label of Consignment (0110dc), Specimen Copy of Label (0110FS), Registration Certificate (Drugs) (101dc1), FSSAI Import Licence (911001), and Import Licence for Drugs (9111dc), as applicable to the consignment's regulatory category. Comply with CBIC Circular 23/2023-Cus (effective 15 October 2023) by including mandatory additional qualifiers in the import declaration for Chapter 29 commodities.CBIC Circular 23/2023-Cus dated 30-09-2023 · CBIC Instruction 09/2023-Cus dated 07-03-2023 · CBIC Instruction 10/2022-Cus dated 28-06-2022
- 3Where the substance is imported for medical or scientific purposes under the NDPS regime, obtain an import certificate under Rule 53 of the NDPS Rules, 1985 through the Narcotics Commissioner (http://cbn.nic.in). Imports outside the medical and scientific category are governed by Appendix I to the ITC (HS) Schedule under policy condition 2 of Chapter 29. Additionally, for food-grade imports, ensure entry only through the designated food-import ports listed under General Note 4(D) of Schedule I of the ITC (HS) 2022.Rule 53 of the NDPS Rules, 1985 · ITC (HS) policy condition 2 of Chapter 29 · General Note 4(D) of Schedule I of the ITC (HS) 2022
The most prevalent error on this tariff line is importing lecithin under a single regulatory assumption — treating it as purely food-grade and uploading only the FSSAI licence — without checking whether the specific formulation also falls within the Schedule to the Insecticides Act, 1968. A lecithin-based formulation meeting the Schedule criteria requires a separate CIB&RC registration and port-restricted import permit; absent that permit, the consignment is liable to detention under Rule 45 of the Insecticides Rules, 1971 regardless of FSSAI clearance. The Chapter 29 mandatory qualifiers under CBIC Circular 23/2023-Cus are a distinct and parallel obligation that applies to all Chapter 29 import declarations effective 15 October 2023.