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Vinyl acetate polymers in aqueous dispersion, other grades

CBIC CLEARANCE

HSN 3905 12 90 (poly(vinyl acetate) and other vinyl ester polymers in aqueous dispersion, residual grades) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls at the bill-of-entry stage. Importers must furnish mandatory additional qualifiers in the import declaration under Chapter 39 per CBIC Circular 23/2023-Cus, and must demonstrate registration on the Centralised EPR Portal for Plastic Packaging under CBIC Instruction 21/2025-Customs.

What this is
HSN code
3905 12 90
Chapter
39 · Plastics and articles thereof
Primary regulator
CBIC · Mandatory Chapter 39 qualifiers and EPR portal registration, CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs
Customs documentation
  • Chapter 39 qualifiers from CBIC
  • EPR portal registration proof from CPCB
  • Import declaration from CBIC
Compliance steps
  1. 1
    File the import declaration with the mandatory additional qualifiers for Chapter 39 commodities as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus with effect from 15 October 2023. Incomplete or absent qualifiers will prevent out-of-charge at the bill-of-entry stage.
    CBIC Circular 23/2023-Cus dated 30-09-2023 · Para 4.1 and 4.2
  2. 2
    Obtain and present proof of registration on the Centralised EPR Portal for Plastic Packaging as required under CBIC Instruction 21/2025-Customs dated 02-07-2025. The proper officer is directed to verify this registration before granting out-of-charge for consignments of plastic polymers in primary forms.
    CBIC Instruction 21/2025-Customs dated 02-07-2025
A word of counsel

The most common error on this tariff line is treating the Chapter 39 mandatory qualifiers as a clerical formality and submitting an incomplete declaration, then discovering the EPR portal registration requirement only at the port. Both obligations are verified concurrently by the proper officer: a consignment that satisfies the qualifiers but lacks the EPR portal registration proof is held at the port, accruing demurrage and ground rent until the registration is produced.

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Frequently asked
Does HSN 3905 12 90 require BIS certification?
No, poly(vinyl acetate) and other vinyl ester polymers in aqueous dispersion are not covered by any BIS Quality Control Order. Import compliance is governed by CBIC Circular 23/2023-Cus, which mandates additional qualifiers in the import declaration for Chapter 39 commodities, and CBIC Instruction 21/2025-Customs on EPR portal registration.
What are the mandatory additional qualifiers required in the import declaration for this HSN?
Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30 September 2023 specify the additional qualifiers applicable to Chapters 28, 29, 32, 39 and CTH 3808; these have been mandatory at the bill-of-entry stage with effect from 15 October 2023.
Which authority issues the EPR portal registration that must be verified at the port?
Registration is on the Centralised EPR Portal for Plastic Packaging; CBIC Instruction 21/2025-Customs dated 02-07-2025 directs proper officers to verify proof of this registration before granting out-of-charge for plastic polymer consignments under Chapter 39.
Last verified against gazette notifications: 2026-05-16. Source: CBIC / Indian Customs CUSDATA.
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