Lacquers

Polyester-based lacquers in non-aqueous medium

CBIC CLEARANCE

HSN 3208 10 20 (Lacquers) is subject to mandatory additional qualifier declarations administered by the Central Board of Indirect Taxes and Customs (CBIC) under CBIC Circular 23/2023-Cus dated 30-09-2023. Importers must include the Chapter 32 qualifiers stipulated in Paragraphs 4.1 and 4.2 of that Circular in every import declaration, with effect from 15 October 2023.

What this is

HSN code

3208 10 20

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 (mandatory Chapter 32 qualifiers)

Customs documentation

Chapter 32 qualifiers from CBIC
Import declaration to CBIC

Compliance steps

1
Include all mandatory additional qualifiers for Chapter 32 commodities as stipulated in Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus in the import declaration at the bill-of-entry stage. This requirement has been operative from 15 October 2023 and applies to all consignments under this tariff line.
CBIC Circular 23/2023-Cus dated 30-09-2023, Paragraphs 4.1 and 4.2
2
Verify that the qualifier details accurately describe the chemical composition and polymer base of the lacquer — polyester-based, dissolved or dispersed in a non-aqueous medium — since misdeclaration of qualifiers constitutes a customs declaration offence under the Customs Act, 1962.
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 without the Chapter 32 mandatory qualifiers, treating the lacquer as a standard paint import with no additional declaration burden. A qualifier-deficient declaration is flagged at e-Sanchit verification and results in consignment detention, with demurrage and ground rent accruing until the declaration is corrected and re-submitted — the Circular provides no post-arrival rectification window that suspends port charges.

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Frequently asked

Does HSN 3208 10 20 require BIS certification?

No, no BIS Quality Control Order covers polyester-based lacquers under this tariff line. The operative compliance requirement is the mandatory additional qualifier declaration under CBIC Circular 23/2023-Cus dated 30-09-2023, applicable with effect from 15 October 2023.

Which chapters are covered by the mandatory qualifier requirement under CBIC Circular 23/2023-Cus?

The Circular applies to import declarations for commodities under Chapters 28, 29, 32 and 39 and CTH 3808; HSN 3208 10 20 falls within Chapter 32 and is subject to the qualifiers in Paragraphs 4.1 and 4.2.

What happens if the Chapter 32 qualifiers are omitted from the bill of entry?

A declaration filed without the mandatory qualifiers is non-compliant with CBIC Circular 23/2023-Cus and exposes the consignment to detention at the port of import, 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.