Varnishes

Acrylic or vinyl polymer varnishes, non-aqueous medium

CBIC CLEARANCE

HSN 3208 20 30 (Varnishes) is subject to the Central Board of Indirect Taxes and Customs (CBIC) mandatory-qualifier regime under CBIC Circular 23/2023-Cus dated 30-09-2023, which requires additional qualifiers in import declarations for all commodities under Chapter 32 with effect from 15 October 2023. No separate PGA licence or permit is required, but non-compliance with the declaration-qualifier obligation at the bill-of-entry stage triggers customs examination and potential hold on out-of-charge.

What this is

HSN code

3208 20 30

Chapter

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

Primary regulator

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

Customs documentation

Chapter 32 qualifiers from CBIC
Import declaration from CBIC

Compliance steps

1
Include all mandatory additional qualifiers in the import declaration as stipulated in Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus for Chapter 32 commodities. Declarations filed without the required qualifiers are liable to be flagged for examination and will not receive out-of-charge.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2, effective 15-10-2023
2
Verify at the bill-of-entry stage that the commodity description and qualifier fields correctly identify the product as a non-aqueous acrylic or vinyl polymer-based varnish under Chapter 32. Misclassification across Chapters 28, 29, 32, 39 or CTH 3808 can trigger re-assessment under the same circular.
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 introduced by CBIC Circular 23/2023-Cus, on the assumption that acrylic varnishes carry no PGA overlay. The qualifier obligation is a customs-declaration requirement — not a separate licence — and its omission is detected at the first system check; the resulting examination hold generates demurrage and ground rent while the importer files a revised declaration.

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Frequently asked

Does HSN 3208 20 30 require BIS certification?

No, acrylic or vinyl polymer varnishes in a non-aqueous medium are not covered by any BIS Quality Control Order. Import compliance is governed by the Central Board of Indirect Taxes and Customs mandatory-qualifier regime under CBIC Circular 23/2023-Cus dated 30-09-2023.

Which specific qualifiers are required in the import declaration for Chapter 32 under CBIC Circular 23/2023-Cus?

The qualifiers are set out in Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus and apply to commodities under Chapters 28, 29, 32, 39 and CTH 3808 with effect from 15 October 2023; importers should consult the circular annexure for the field-level specification.

Does the CBIC qualifier obligation apply to samples or small-quantity trial imports of this varnish?

The circular does not carve out an exemption for samples or trial quantities; all import declarations for Chapter 32 commodities filed on or after 15 October 2023 are required to carry the mandatory qualifiers regardless of consignment value or quantity.

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