D-or DL-Pantothenic acid (Vitamin B5) and its derivatives
D- or DL-Pantothenic acid (Vitamin B5) and its derivatives
HSN 2936 24 00 (D- or DL-Pantothenic acid and its derivatives) is subject to Food Safety and Standards Authority of India (FSSAI) Import Licence requirements under the Food Safety and Standards Act, 2006, with a concurrent Narcotic Drugs and Psychotropic Substances (NDPS) regime overlay under Chapter VII-A of the NDPS Rules, 1985. The Directorate General of Foreign Trade (DGFT) classifies this tariff line under ITC (HS) policy condition 2 of Chapter 29, and mandatory Chapter 29 qualifiers in import declarations apply from 15 October 2023 under CBIC Circular 23/2023-Cus.
- Import Licence from FSSAI
- Registration certificate from CDSCO
- Certificate of Analysis from supplier
Procedural directions for customs clearance are issued by: Directorate General of Foreign Trade, Central Board of Indirect Taxes and Customs.
- 1Obtain an FSSAI Import Licence (document code 911001) and ensure the foreign manufacturing facility is registered. Upload in e-Sanchit the FSSAI Import Licence (911001), Specimen Copy of Label (0110FS), and confirm compliance with the rectifiable-labelling regime under CBIC Instruction 09/2023-Cus and FSSAI order dated 18-11-2022 before out-of-charge.CBIC Instruction 09/2023-Cus dated 07-03-2023; CBIC Instruction 10/2022-Cus dated 28-06-2022; FSSAI order dated 18-11-2022 under F.No. Import/TFM/Apex/2022-FSSAI
- 2If the substance qualifies as an NDPS substance, obtain an import certificate under Rule 53 of the NDPS Rules, 1985 for import under the special provision for medical and scientific purposes (Chapter VII-A). Upload the Certificate of Analysis — Drug (0010dc), Batch Release Certificate (0030dc), Label of Consignment (0110dc), Registration Certificate — Drugs (101dc1), and Import Licence for Drugs (9111dc) in e-Sanchit before out-of-charge. Imports outside the medical/scientific category are governed by Appendix-I to the ITC (HS) Schedule.Rule 53 of the NDPS Rules, 1985; ITC (HS) policy condition 2 of Chapter 29
- 3Include 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, applicable with effect from 15 October 2023. Failure to include the Chapter 29 qualifiers renders the bill of entry non-compliant and liable to detention pending re-filing.CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2
The most frequent error on this tariff line is treating the FSSAI Import Licence as the sole clearance and overlooking the NDPS overlay, which applies independently: even a substance primarily traded as a vitamin intermediate may fall within the NDPS Rules, 1985 if the import purpose or the substance's scheduling so warrants. An NDPS-applicable consignment cleared without a Rule 53 import certificate is liable to seizure under the NDPS Act regardless of the FSSAI clearance status. Confirm the substance's NDPS scheduling with the Central Bureau of Narcotics before dispatch.