Blacks

Synthetic organic black colouring matter, dye mixtures

CBIC CLEARANCE

HSN 3204 19 78 (Blacks) is subject to mandatory additional chemical qualifiers in the import declaration under Central Board of Indirect Taxes and Customs (CBIC) Circular 23/2023-Cus dated 30-09-2023, operative from 15 October 2023. The qualifier requirements apply to all commodities under Chapters 28, 29, 32, 39 and CTH 3808 as stipulated in paragraphs 4.1 and 4.2 of that Circular.

What this is

HSN code

3204 19 78

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
Commercial invoice from exporter

Compliance steps

1
At the time of filing the bill of entry, ensure the import declaration includes all mandatory additional chemical qualifiers for Chapter 32 commodities as specified in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. Declarations filed without the required qualifiers are liable to be treated as incomplete, resulting in consignment detention.
CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2, effective 15-10-2023
2
Confirm that the specific chemical identity, CAS number, or compositional description of the black colouring matter is stated in the import declaration, as Chapter 32 qualifier requirements are designed to distinguish synthetic organic colouring matter from inorganic and other dye families covered by adjacent headings.
CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2

A word of counsel

The most common error on this tariff line is submitting a generic product description — 'black dye' or 'synthetic colourant' — without the Chapter 32 chemical qualifiers mandated since 15 October 2023. A bill of entry that omits the qualifiers specified in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus will be flagged at the first-appraisement stage, attracting hold, demurrage, and ground rent while the declaration is rectified.

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Frequently asked

Does HSN 3204 19 78 require BIS certification?

No; no BIS Quality Control Order covers synthetic organic black colouring matter under this tariff line. Import compliance is governed by the Central Board of Indirect Taxes and Customs under Circular 23/2023-Cus, which mandates additional chemical qualifiers in the import declaration for Chapter 32 commodities effective 15 October 2023.

What specific qualifiers must appear in the import declaration for Chapter 32 goods under Circular 23/2023-Cus?

Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus specify the mandatory additional qualifiers for Chapters 28, 29, 32, 39 and CTH 3808; the precise field requirements should be confirmed against the Circular's annexure before filing.

Does the qualifier requirement under Circular 23/2023-Cus apply to mixtures of black colouring matter from different sub-headings?

Yes. HSN 3204 19 78 falls within the residual 'Other, including mixtures of colouring matter of two or more of sub-headings 3204 11 to 3204 19' family, and Chapter 32 qualifier obligations under Circular 23/2023-Cus apply to all qualifying commodities within that chapter without exception for mixtures.

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