Styrene-acrylonitrile (SAN) copolymers

Styrene-acrylonitrile (SAN) copolymers, plastics primary forms

CBIC CLEARANCE

HSN 3903 20 00 (Styrene-acrylonitrile (SAN) copolymers) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls requiring mandatory additional qualifiers in import declarations under Chapter 39, operative from 15 October 2023 per CBIC Circular 23/2023-Cus. Importers must also furnish proof of registration on the Centralised EPR Portal for Plastic Packaging, as mandated by CBIC Instruction 21/2025-Customs dated 02-07-2025.

What this is

HSN code

3903 20 00

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · Mandatory Chapter 39 qualifiers and EPR portal registration, CBIC Circular 23/2023-Cus and Instruction 21/2025-Customs

Customs documentation

EPR portal registration proof from CBIC
Chapter 39 qualifiers from CBIC

Compliance steps

1
At the bill of entry, include mandatory additional qualifiers for Chapter 39 commodities as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers are compulsory for all import declarations covering HSNs under Chapters 28, 29, 32, 39 and CTH 3808, with effect from 15 October 2023.
CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2
2
Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before the bill of entry is processed. Failure to produce valid EPR registration proof will prevent out-of-charge clearance.
CBIC Instruction 21/2025-Customs dated 02-07-2025

A word of counsel

The most common error on this tariff line is filing the bill of entry with complete commercial documentation but omitting the Chapter 39 mandatory qualifiers required under CBIC Circular 23/2023-Cus — a deficiency that triggers amendment, detention, and demurrage even when the goods themselves are fully compliant. The EPR portal registration requirement under CBIC Instruction 21/2025-Customs is a separate, independent obligation: current commercial and CBIC documentary compliance does not substitute for a live EPR registration.

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Frequently asked

Does HSN 3903 20 00 require BIS certification?

No, styrene-acrylonitrile copolymers in primary forms are not covered by any BIS Quality Control Order. Import compliance is governed by Central Board of Indirect Taxes and Customs policy controls, specifically the Chapter 39 mandatory qualifier regime under CBIC Circular 23/2023-Cus and the EPR portal registration requirement under CBIC Instruction 21/2025-Customs.

What are the mandatory qualifiers required for the Chapter 39 import declaration?

The qualifiers are prescribed in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30 September 2023, applicable to commodities under Chapters 28, 29, 32, 39 and CTH 3808, mandatory from 15 October 2023.

Does the EPR portal registration requirement apply to all importers of SAN copolymers?

Yes. CBIC Instruction 21/2025-Customs dated 02-07-2025 requires verification of proof of registration on the Centralised EPR Portal for Plastic Packaging at the bill of entry stage, with no exemption carved out for volume or end-use.

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