Other

Vinylidene chloride polymers in primary forms, other

CBIC CLEARANCE

HSN 3904 50 90 (Vinylidene chloride polymers — Other) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy overlays requiring verification of Extended Producer Responsibility (EPR) registration on the centralised EPR portal for plastic packaging under CBIC Instruction 21/2025-Customs dated 02-07-2025. Mandatory additional qualifiers in the import declaration for Chapter 39 commodities apply under CBIC Circular 23/2023-Cus dated 30-09-2023, effective 15 October 2023.

What this is

HSN code

3904 50 90

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs

Customs documentation

EPR portal registration proof from CBIC
Chapter 39 mandatory qualifiers from CBIC

Compliance steps

1
Verify that the importer holds valid registration on the centralised EPR portal for plastic packaging and upload proof of such registration at the bill of entry. Non-compliance with this requirement is an enforcement trigger under CBIC Instruction 21/2025-Customs dated 02-07-2025.
CBIC Instruction 21/2025-Customs dated 02-07-2025
2
Include all mandatory additional qualifiers in the import declaration for Chapter 39 commodities as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. This obligation has been operative since 15 October 2023 and applies to every bill of entry covering this tariff line.
CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2, effective 15-10-2023

A word of counsel

The most common error on this tariff line is filing the import declaration with correct classification but omitting the Chapter 39 mandatory qualifiers required under CBIC Circular 23/2023-Cus — a deficiency that triggers a mismatch flag at the customs system level and results in consignment detention pending a corrected declaration. EPR portal registration is a separate, concurrent obligation; possessing one without the other is treated as partial non-compliance and does not secure out-of-charge.

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Frequently asked

Does HSN 3904 50 90 require BIS certification?

No, vinylidene chloride polymers in primary forms are not covered by any BIS Quality Control Order. Import is governed by CBIC policy overlays — specifically EPR portal registration for plastic packaging under CBIC Instruction 21/2025-Customs and mandatory Chapter 39 qualifiers under CBIC Circular 23/2023-Cus.

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

Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus specify the additional qualifier fields that must be populated in import declarations for Chapter 39 commodities; these have been mandatory since 15 October 2023 and must be completed at the bill-of-entry stage.

When did the EPR portal registration requirement for plastic packaging take effect?

The requirement to verify and submit proof of registration on the centralised EPR portal for plastic packaging was introduced by CBIC Instruction 21/2025-Customs dated 02-07-2025 and applies to all in-scope plastic packaging imports from that date.

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