Enamels

Polyester-based enamel paints and varnishes

CBIC CLEARANCE

HSN 3208 10 10 (Enamels) is subject to Central Board of Indirect Taxes and Customs (CBIC) mandatory additional-qualifier requirements in import declarations under CBIC Circular 23/2023-Cus dated 30-09-2023. Importers must include the Chapter 32 qualifiers specified in Para 4.1 and 4.2 of that Circular in all bills of entry filed on or after 15 October 2023.

What this is

HSN code

3208 10 10

Chapter

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

Primary regulator

CBIC · CBIC Circular 23/2023-Cus, Chapter 32 mandatory qualifiers

Customs documentation

Chapter 32 qualifiers from CBIC
Import declaration from CBIC

Compliance steps

1
Include all mandatory additional qualifiers for Chapter 32 commodities in the import declaration at the bill of entry stage, as stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers are required for all bills of entry filed on or after 15 October 2023.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2
2
Verify that the qualifier fields in the import declaration accurately describe the polyester-base chemistry and solvent medium of the enamel product, as the qualifier regime applies across Chapters 28, 29, 32, 39 and CTH 3808. Incomplete or inaccurate qualifiers may result in bill-of-entry rejection or detention.
CBIC Circular 23/2023-Cus dated 30-09-2023

A word of counsel

The most common error on this tariff line is filing the bill of entry with generic product descriptions and omitting the Chapter 32 mandatory qualifiers entirely, treating them as optional supplementary information. CBIC Circular 23/2023-Cus makes these qualifiers a hard requirement from 15 October 2023; a declaration filed without the Para 4.1 and 4.2 fields populated exposes the consignment to detention and re-filing costs, not merely a technical query.

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Frequently asked

Does HSN 3208 10 10 require BIS certification?

No, polyester-based enamel paints are not covered by any BIS Quality Control Order. The operative compliance obligation is the CBIC mandatory additional-qualifier requirement under CBIC Circular 23/2023-Cus dated 30-09-2023, applicable to all Chapter 32 import declarations from 15 October 2023.

Which specific qualifiers are required in the import declaration for HSN 3208 10 10?

The qualifiers are those stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus; the Circular covers commodities under Chapters 28, 29, 32, 39 and CTH 3808, and the specific field requirements should be read directly from that Circular before filing.

What happens if the mandatory qualifiers are missing from the bill of entry?

A bill of entry lacking the Chapter 32 qualifiers required under CBIC Circular 23/2023-Cus is liable to rejection or detention at the port, with demurrage and ground rent accruing until a corrected declaration is accepted by the proper officer.

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