Emulsion paints not elsewhere specified or included

Emulsion paints, aqueous-medium synthetic polymer paints

CBIC CLEARANCE

HSN 3209 90 20 (Emulsion paints not elsewhere specified or included) is subject to mandatory additional qualifier declarations in the import entry administered by the Central Board of Indirect Taxes and Customs (CBIC) under CBIC Circular 23/2023-Cus dated 30-09-2023. This requirement, operative from 15 October 2023, applies to all import declarations for commodities under Chapter 32 as stipulated in paragraphs 4.1 and 4.2 of that Circular.

What this is

HSN code

3209 90 20

Chapter

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

Primary regulator

CBIC · CBIC Circular 23/2023-Cus dated 30-09-2023 (Chapter 32 mandatory qualifiers)

Customs documentation

Chapter 32 qualifiers from CBIC
Import declaration to CBIC

Compliance steps

1
Include all mandatory additional qualifiers in the import declaration for HSN 3209 90 20 as prescribed in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers are mandatory for all consignments filed on or after 15 October 2023, and a declaration lacking required qualifiers will be rejected at the bill-of-entry stage.
CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2
2
Verify that the qualifier entries accurately describe the imported emulsion paint — covering the relevant chemical composition or polymer base — as the Chapter 32 qualifier regime applies across Chapters 28, 29, 32, 39 and CTH 3808. Incorrect or missing qualifiers expose the consignment to detention and a request for re-presentation of the bill of entry.
CBIC Circular 23/2023-Cus dated 30-09-2023

A word of counsel

The single most common error on this tariff line is filing the bill of entry without populating the Chapter 32 mandatory qualifier fields, treating them as optional descriptive metadata rather than a hard clearance prerequisite. A bill of entry filed without the qualifiers stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus is liable to be held at the port pending amendment, accruing demurrage and ground rent until the corrected declaration is accepted.

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Frequently asked

Does HSN 3209 90 20 require BIS certification?

No, emulsion paints under this tariff line are not covered by any BIS Quality Control Order. The operative compliance requirement is the mandatory additional qualifier declaration under CBIC Circular 23/2023-Cus dated 30-09-2023, administered by the Central Board of Indirect Taxes and Customs.

From which date are the Chapter 32 mandatory qualifiers enforceable, and where are they specified?

The mandatory additional qualifier requirements are enforceable from 15 October 2023, as prescribed in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023, covering Chapter 32 commodities including emulsion paints.

Do the mandatory qualifier requirements under CBIC Circular 23/2023-Cus apply only to Chapter 32, or to other chapters as well?

The Circular applies across Chapters 28, 29, 32, 39 and CTH 3808; HSN 3209 90 20 falls squarely within Chapter 32 and is therefore subject to the qualifier declarations in every import consignment.

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