Other

Other halogenated olefin polymers in primary forms

CBIC CLEARANCE

HSN 3904 69 90 (Other polymers of vinyl chloride or other halogenated olefins, primary forms) is subject to Central Board of Indirect Taxes and Customs (CBIC) compliance requirements, including mandatory Chapter 39 additional qualifiers in import declarations and Extended Producer Responsibility (EPR) portal registration verification for plastic packaging. Both requirements apply at the bill-of-entry stage with effect from 15 October 2023 and 2 July 2025 respectively.

What this is

HSN code

3904 69 90

Chapter

39 · Plastics and articles thereof

Primary regulator

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

Customs documentation

EPR registration proof from centralised EPR portal
Chapter 39 qualifiers declaration from CBIC
Import declaration with mandatory qualifiers

Compliance steps

1
Include mandatory additional qualifiers in the import declaration as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus for commodities under Chapter 39. This requirement has been operative with effect from 15 October 2023 and non-compliant declarations are liable to be held up at assessment.
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 filing the bill of entry. Customs officers are required to verify this registration proof per CBIC Instruction 21/2025-Customs, and consignments without valid EPR registration documentation are subject to detention.
CBIC Instruction 21/2025-Customs dated 02-07-2025

A word of counsel

The most common error on this tariff line is completing the Chapter 39 qualifier requirements under CBIC Circular 23/2023-Cus while overlooking the separate EPR portal registration verification introduced by CBIC Instruction 21/2025-Customs. The two obligations are independent: a declaration that satisfies the qualifier regime may still be detained if proof of EPR registration on the centralised portal is absent or not uploaded, since customs verification of EPR status is now a standalone pre-out-of-charge check.

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Frequently asked

Does HSN 3904 69 90 require BIS certification?

No, no BIS Quality Control Order covers this residual category of halogenated olefin polymers in primary forms. Import is governed by CBIC-administered requirements, specifically the Chapter 39 mandatory qualifier regime under CBIC Circular 23/2023-Cus and the EPR portal registration verification under CBIC Instruction 21/2025-Customs.

What are the mandatory additional qualifiers required for Chapter 39 imports under CBIC Circular 23/2023-Cus?

Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus, operative from 15 October 2023, specify the mandatory additional qualifiers for import declarations covering Chapters 28, 29, 32, 39 and CTH 3808; the exact qualifier fields must be populated in the import declaration before assessment.

Does the EPR portal registration requirement apply to importers or to foreign manufacturers?

CBIC Instruction 21/2025-Customs dated 02 July 2025 requires verification of proof of registration on the centralised EPR portal for plastic packaging at the import stage; the importer is responsible for presenting this proof at the bill-of-entry stage.

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