Poly (vinyl acetate) (PVA) moulding material

Poly (vinyl acetate) PVA moulding material in primary forms

CBIC CLEARANCE

HSN 3905 19 10 (Poly (vinyl acetate) PVA moulding material) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls, including mandatory Chapter 39 additional qualifiers in import declarations and Extended Producer Responsibility (EPR) registration verification for plastic packaging. CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs apply as overlapping compliance requirements at the bill-of-entry stage.

What this is

HSN code

3905 19 10

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · ITC (HS) import policy with Chapter 39 mandatory qualifiers and EPR portal verification

Customs documentation

EPR registration proof from CPCB portal
Chapter 39 qualifiers declaration from CBIC
Import declaration 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. Failure to demonstrate valid EPR registration invites out-of-charge denial under CBIC Instruction 21/2025-Customs.
CBIC Instruction 21/2025-Customs 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, with effect from 15 October 2023. Declarations filed without the prescribed qualifiers are treated as non-compliant and subject to detention.
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 treating the Chapter 39 mandatory-qualifier requirement and the EPR portal registration as independent, sequential checks rather than concurrent obligations both verified at out-of-charge. A consignment may carry a fully compliant import declaration with all Chapter 39 qualifiers and still be detained if the EPR registration proof has not been uploaded, because CBIC Instruction 21/2025-Customs operates as a separate gate from the qualifier regime introduced by Circular 23/2023-Cus.

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Frequently asked

Does HSN 3905 19 10 require BIS certification?

No, no BIS Quality Control Order covers poly (vinyl acetate) PVA moulding material in primary forms. Import is governed by Central Board of Indirect Taxes and Customs policy controls under CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs, covering mandatory Chapter 39 qualifiers and EPR portal registration.

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

Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30 September 2023 prescribe the mandatory additional qualifiers for commodities under Chapters 28, 29, 32, 39 and CTH 3808, effective 15 October 2023; the specific qualifier fields must be populated in the import declaration at the bill-of-entry stage.

Does the EPR registration obligation apply even for small or one-time import consignments of PVA moulding material?

CBIC Instruction 21/2025-Customs dated 02 July 2025 requires verification of proof of registration on the Centralised EPR Portal for Plastic Packaging without a de minimis carve-out; importers should confirm their registration status on the portal before each consignment.

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