4-Anilino-N-phenethylpiperidine(ANPP)
ANPP, a fentanyl precursor piperidine compound
HSN 2933 36 00 (4-Anilino-N-phenethylpiperidine, ANPP) is subject to consignment-wise NOC from the Narcotics Commissioner under the NDPS (Regulation of Controlled Substances) Order, 2013, as a designated controlled substance. Where ANPP also 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, with import restricted to specified places under Rule 45 of the Insecticides Rules, 1971. Directorate General of Foreign Trade (DGFT) policy controls and mandatory Chapter 29 qualifiers under CBIC Circular 23/2023-Cus apply as customs-layer overlays.
- Consignment-wise NOC from Narcotics Commissioner
- Registration and 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.
- 1Obtain a consignment-wise NOC from the Narcotics Commissioner before each shipment of ANPP or NPP. This NOC is a pre-import mandatory clearance for controlled substances under the NDPS (Regulation of Controlled Substances) Order, 2013, and must be secured per consignment — a single standing NOC does not satisfy the requirement.NDPS (Regulation of Controlled Substances) Order, 2013 dated 26-03-2013 · DGFT Notification 15/2015-20 dated 21-07-2015
- 2Where ANPP is classified under the Schedule to the Insecticides Act, 1968, secure registration and an import permit from the CIB&RC Secretariat prior to dispatch. Import must be routed through places specified under Rule 45 of the Insecticides Rules, 1971; consignments arriving at non-specified ports are liable to detention.Insecticides Act, 1968 · Rule 45 of the Insecticides Rules, 1971
- 3File mandatory additional qualifiers in the import declaration for Chapter 29 commodities as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus, effective 15 October 2023. For imports of specified hazardous substances exceeding prescribed quantities, obtain an insurance policy under the Public Liability Insurance Act, 1991.CBIC Circular 23/2023-Cus dated 30-09-2023 · S.O. 227(E) dated 24-03-1992
The most consequential error on this tariff line is treating the NDPS NOC as a one-time or annual clearance rather than a per-consignment obligation — each shipment requires a fresh NOC from the Narcotics Commissioner, and bills of entry filed without the current consignment-specific NOC are detained at the port of import, attracting NDPS enforcement consequences including confiscation and prosecution. Importers who also require CIB&RC registration for the pesticide schedule should note that the two regulatory tracks are independent: satisfying the NDPS regime does not satisfy the Insecticides Act requirements, and both clearances must be simultaneously valid at the bill-of-entry stage.