Poly (vinyl acetate) (PVA), moulding material

Poly (vinyl acetate) in aqueous dispersion, moulding material

CBIC CLEARANCE

HSN 3905 12 10 (Poly (vinyl acetate) moulding material in aqueous dispersion) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls governing Chapter 39 plastic commodities, including mandatory additional qualifiers in import declarations under CBIC Circular 23/2023-Cus and Extended Producer Responsibility (EPR) registration verification under CBIC Instruction 21/2025-Cus. Both requirements apply at the bill-of-entry stage before out-of-charge is granted.

What this is

HSN code

3905 12 10

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · Chapter 39 mandatory qualifiers and EPR portal compliance

Customs documentation

EPR registration proof from CBIC portal
Chapter 39 qualifiers from CBIC

Compliance steps

1
Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before filing the bill of entry. Consignments without valid EPR registration documentation will not receive out-of-charge under CBIC Instruction 21/2025-Cus.
CBIC Instruction 21/2025-Cus dated 02-07-2025
2
Include the mandatory additional qualifiers in the import declaration for Chapter 39 commodities as stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus. This requirement is operative with effect from 15 October 2023 and applies to all imports under Chapter 39.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2

A word of counsel

The most common error on this tariff line is filing the bill of entry with the standard Chapter 39 commodity description and omitting the additional qualifiers mandated under Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus. A declaration lacking these qualifiers is treated as incomplete, resulting in consignment detention and demurrage while the entry is recalled for amendment. The EPR portal registration and the Chapter 39 qualifiers are independent obligations — satisfying one does not discharge the other.

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Frequently asked

Does HSN 3905 12 10 require BIS certification?

No, poly (vinyl acetate) moulding material in aqueous dispersion is not covered by any BIS Quality Control Order. Import is governed by CBIC policy controls under CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Cus, covering Chapter 39 declaration qualifiers and EPR portal registration respectively.

Which additional qualifiers are mandatory in the import declaration for Chapter 39 under CBIC Circular 23/2023-Cus?

Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus specify the mandatory additional qualifiers for import declarations covering commodities under Chapters 28, 29, 32, 39 and CTH 3808; the circular should be consulted for the exact qualifier fields applicable to each sub-heading.

What happens if the EPR portal registration is not in place at the time of import?

Absence of valid proof of registration on the Centralised EPR Portal for Plastic Packaging prevents out-of-charge clearance under CBIC Instruction 21/2025-Cus, exposing the consignment to detention, demurrage, and ground rent until compliance is established.

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