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Other halogenated olefin polymers in primary forms

DGFT CLEARANCE · CBIC CLEARANCE

HSN 3904 90 90 (Other halogenated olefin polymers in primary forms) is subject to the Directorate General of Foreign Trade (DGFT) ITC (HS) import policy, including Tariff Rate Quota conditions under the India-UAE Comprehensive Economic Partnership Agreement (CEPA). Central Board of Indirect Taxes and Customs (CBIC) mandatory Chapter 39 additional qualifiers at the bill-of-entry stage and Extended Producer Responsibility (EPR) portal registration verification apply as concurrent customs-level overlays.

What this is
HSN code
3904 90 90
Chapter
39 · Plastics and articles thereof
Primary regulator
DGFT · ITC (HS) import policy, FTP 2015-20 Appendix 2A, India-UAE CEPA TRQ
Customs documentation
  • TRQ allocation certificate from DGFT
  • EPR portal registration proof from CPCB
  • Chapter 39 qualifiers from CBIC
Compliance steps
  1. 1
    Verify whether the consignment qualifies for import under the Tariff Rate Quota notified under the India-UAE CEPA. If importing under TRQ, comply with the allocation and import procedures in Annexure IV of Appendix 2A of FTP 2015-20 as amended, and ensure the relevant DGFT allocation certificate accompanies the bill of entry.
    DGFT Public Notice 6/2015-2020 dated 01-05-2022; CBIC Notification 22/2022-Customs dated 30-04-2022; CBIC Notification 43/2022-Customs dated 20-07-2022; DGFT Public Notice 23/2015-2020 dated 29-08-2022
  2. 2
    Upload proof of registration on the centralised EPR portal for plastic packaging before customs out-of-charge. CBIC Instruction 21/2025-Customs dated 02-07-2025 mandates verification of this registration at the bill-of-entry stage; consignments without a valid EPR registration are liable to detention.
    CBIC Instruction 21/2025-Customs dated 02-07-2025
  3. 3
    Include 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-Customs dated 30-09-2023, with effect from 15-10-2023. Declarations filed without the prescribed qualifiers are treated as non-compliant at first-check.
    CBIC Circular 23/2023-Customs dated 30-09-2023, Paragraphs 4.1 and 4.2
A word of counsel

The most common error on this tariff line is overlooking the EPR plastic-packaging registration requirement when the immediate commercial focus is on the CEPA TRQ benefit. The EPR portal registration under CBIC Instruction 21/2025-Customs is a standalone customs-verification obligation independent of tariff classification or preferential-origin status; a consignment with a valid TRQ allocation but an unregistered EPR account will be detained at the port of entry, attracting demurrage and ground rent while the registration is remedied.

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Frequently asked
Does HSN 3904 90 90 require BIS certification?
No, halogenated olefin polymers in primary forms are not covered by any BIS Quality Control Order. Import is governed by DGFT ITC (HS) policy — including India-UAE CEPA Tariff Rate Quota conditions — and CBIC customs-level overlays on EPR registration and mandatory Chapter 39 declaration qualifiers.
What are the mandatory additional qualifiers required in the import declaration for this HSN?
CBIC Circular 23/2023-Customs dated 30-09-2023 mandates specific additional qualifiers for import declarations covering Chapter 39 commodities (including CTH 3904) as set out in Paragraphs 4.1 and 4.2, applicable with effect from 15 October 2023.
Does every importer of HSN 3904 90 90 need to register on the centralised EPR portal for plastic packaging?
Yes. CBIC Instruction 21/2025-Customs dated 02-07-2025 requires customs officers to verify proof of registration on the centralised EPR portal for plastic packaging for consignments under this tariff line before granting out-of-charge.
Last verified against gazette notifications: 2026-05-16. Source: DGFT / CBIC / Indian Customs CUSDATA.
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