Other

Water-based paints and varnishes of synthetic polymers, other

CBIC CLEARANCE

HSN 3209 90 90 (other water-based paints and varnishes based on synthetic or chemically modified natural polymers) is subject to mandatory additional qualifier declarations in the import bill of entry, administered by the Central Board of Indirect Taxes and Customs (CBIC) under CBIC Circular 23/2023-Cus dated 30-09-2023. The requirement, operative from 15 October 2023, applies to all commodities under Chapter 32 and obliges the importer to furnish chemical-composition qualifiers at paragraphs 4.1 and 4.2 of that circular.

What this is

HSN code

3209 90 90

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
Bill of entry declaration to CBIC

Compliance steps

1
Before filing the bill of entry, prepare and attach the mandatory additional qualifiers for Chapter 32 commodities as prescribed in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers must be incorporated into the import declaration; non-compliance triggers misdeclaration enforcement under the Customs Act, 1962.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2, operative from 15-10-2023
2
Confirm that the qualifier requirements specific to Chapters 28, 29, 32, 39 and CTH 3808 are all addressed where any co-imported or composite consignment spans those chapters. The circular applies uniformly to all tariff lines within Chapter 32, including the residual 3209 90 90 classification.
CBIC Circular 23/2023-Cus dated 30-09-2023

A word of counsel

The most common error on this residual tariff line is treating the Chapter 32 qualifier obligation as a formality and submitting a bill of entry without the paragraph 4.1 and 4.2 chemical-composition particulars. Customs systems flag the absence of these qualifiers at the assessment stage, resulting in consignment hold and demurrage while an amended declaration is processed; the qualifier requirement has been operative since 15 October 2023 and is not waivable for 3209 90 90.

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Frequently asked

Does HSN 3209 90 90 require BIS certification?

No, no BIS Quality Control Order covers this residual category of water-based paints and varnishes. The operative compliance requirement is the mandatory additional-qualifier declaration under CBIC Circular 23/2023-Cus dated 30-09-2023 for Chapter 32 commodities.

What are the mandatory qualifiers required under CBIC Circular 23/2023-Cus for Chapter 32 imports?

Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus prescribe the specific chemical-composition and classification particulars that must be declared in the import bill of entry for all Chapter 32 tariff lines, effective 15 October 2023.

Does the qualifier obligation under CBIC Circular 23/2023-Cus apply even when only a small quantity of Chapter 32 goods is imported?

Yes, the obligation applies to all imports classified under Chapter 32 regardless of quantity; there is no de minimis carve-out in CBIC Circular 23/2023-Cus.

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