Other
Other synthetic organic colouring matter, dye mixtures
HSN 3204 19 89 (Other synthetic organic colouring matter) is subject to Food Safety and Standards Authority of India (FSSAI) Import Licence controls and designated food-import port restrictions under the Food Safety and Standards Act, 2006, where the colouring matter falls within a food-use category. The Directorate General of Foreign Trade (DGFT) administers the ITC (HS) policy overlay, and Central Board of Indirect Taxes and Customs (CBIC) Circular 23/2023-Cus mandates additional Chapter 32 qualifiers in import declarations with effect from 15 October 2023.
- Import Licence from FSSAI
- Specimen copy of label from FSSAI
- Chapter 32 qualifiers from CBIC
Procedural directions for customs clearance are issued by: Directorate General of Foreign Trade, Central Board of Indirect Taxes and Customs.
- 1Upload the FSSAI Import Licence (document code 911001) and a Specimen Copy of Label (document code 0110FS) in e-Sanchit before filing the bill of entry. Customs out-of-charge will not be granted until both documents are verified as present in e-Sanchit for PGA-facilitated bills.CBIC Instruction 09/2023-Cus dated 07-03-2023 · FSSAI order dated 18-11-2022 under F.No.Import/TFM/Apex/2022-FSSAI
- 2Include mandatory additional qualifiers in the import declaration for this Chapter 32 commodity as stipulated in Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. This requirement applies to all import declarations filed on or after 15 October 2023 and non-compliance renders the bill of entry deficient.CBIC Circular 23/2023-Cus dated 30-09-2023
- 3Route the consignment through a designated food-import entry point and confirm compliance with General Note 4(D) of Schedule I of the ITC (HS) 2022. Any rectifiable labelling deficiency must be remedied at a customs bonded warehouse by affixing a single non-detachable sticker next to the principal display panel before authorised-officer inspection.General Note 4(D) of ITC (HS) Schedule I · CBIC Instruction 10/2022-Cus dated 28-06-2022 · FSSAI clarification order dated 18-11-2022
The most common error on this tariff line is treating HSN 3204 19 89 as a purely industrial chemical entry and omitting the FSSAI Import Licence on the ground that the colouring matter is not a finished food product. Where the substance is imported for food-contact or food-colouring use, FSSAI jurisdiction attaches at the point of import — not at the point of sale — and consignments without a current FSSAI licence and a compliant label specimen are detained pending rectification, accruing demurrage and ground rent during that period.