Pigment blacks

Synthetic organic pigment blacks and preparations

CBIC CLEARANCE

HSN 3204 17 80 (Pigment blacks) is subject to mandatory additional qualifiers in import declarations administered by the Central Board of Indirect Taxes and Customs (CBIC) under CBIC Circular 23/2023-Cus dated 30-09-2023. The requirement applies to all commodities under Chapter 32 and mandates that importers include specified chemical qualifiers at the bill-of-entry stage with effect from 15 October 2023.

What this is

HSN code

3204 17 80

Chapter

32 · Tanning or dyeing extracts; tannins and their derivatives; dyes, pigments, paints and varnishes

Primary regulator

CBIC · Circular 23/2023-Cus dated 30-09-2023 (Chapter 32 mandatory qualifiers)

Customs documentation

Chapter 32 qualifiers from CBIC
Import declaration to CBIC

Compliance steps

1
Ensure the import declaration for HSN 3204 17 80 includes the mandatory additional qualifiers for Chapter 32 commodities as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. Non-compliant declarations filed on or after 15 October 2023 are liable to detention and re-examination by the proper officer.
CBIC Circular 23/2023-Cus dated 30-09-2023, para 4.1 and 4.2
2
Verify that the chemical identity descriptors for the pigment black preparation — including any relevant chemical composition, CAS reference, or trade-name qualifier required under paragraphs 4.1 and 4.2 — are accurately declared at the bill-of-entry stage and consistent with the commercial invoice and technical data sheet.
CBIC Circular 23/2023-Cus dated 30-09-2023, para 4.1 and 4.2

A word of counsel

The single most common failure on this tariff line is submitting a bill of entry that names only the broad product class — 'pigment black' — without the specific chemical qualifiers required under paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. An incomplete qualifier declaration triggers a query or re-examination even when the substantive product is unobjectionable, causing consignment detention and demurrage while corrected documentation is resubmitted. Align the import declaration with the supplier's technical data sheet before filing.

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Frequently asked

Does HSN 3204 17 80 require BIS certification?

No. No BIS Quality Control Order covers synthetic organic pigment blacks under this tariff line. The operative compliance requirement is the CBIC mandatory-qualifier regime under CBIC Circular 23/2023-Cus, which governs import declarations for all Chapter 32 commodities with effect from 15 October 2023.

From which date are the Chapter 32 mandatory qualifiers enforceable at the bill of entry?

The requirement is operative with effect from 15 October 2023, per CBIC Circular 23/2023-Cus dated 30 September 2023; import declarations filed on or after that date must include the qualifiers stipulated in paragraphs 4.1 and 4.2.

Does the mandatory-qualifier obligation under CBIC Circular 23/2023-Cus extend to other chapters beyond Chapter 32?

Yes. The same circular covers commodities under Chapters 28, 29 and 39 and CTH 3808; importers of pigment blacks who also trade in related chemical tariff lines must apply the qualifier discipline across all affected chapters.

Last verified against gazette notifications: 2026-05-16. Source: CBIC / Indian Customs CUSDATA.