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HomeHSNChapter 39HSN 3905 19 20

Poly (vinyl acetate) and resins

Poly (vinyl acetate) polymers and resins in primary forms

CBIC CLEARANCE

HSN 3905 19 20 (Poly (vinyl acetate) and resins) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls, including mandatory Chapter 39 additional qualifiers in import declarations under CBIC Circular 23/2023-Cus dated 30-09-2023. Importers must also verify and declare proof of registration on the Centralised EPR Portal for Plastic Packaging per CBIC Instruction 21/2025-Customs dated 02-07-2025.

What this is
HSN code
3905 19 20
Chapter
39 · Plastics and articles thereof
Primary regulator
CBIC · Mandatory Chapter 39 qualifiers and EPR portal registration, CBIC Circular 23/2023-Cus and Instruction 21/2025-Customs
Customs documentation
  • EPR portal registration proof from CBIC
  • Chapter 39 qualifiers declaration to CBIC
Compliance steps
  1. 1
    Include mandatory additional qualifiers in the import declaration for this Chapter 39 commodity as stipulated in Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. This requirement has been operative with effect from 15 October 2023 for all import declarations covering Chapters 28, 29, 32, 39 and CTH 3808.
    CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2
  2. 2
    Verify and submit proof of registration on the Centralised EPR Portal for Plastic Packaging at the bill-of-entry stage. Non-compliance with this registration verification requirement is a contravention of CBIC Instruction 21/2025-Customs and may result in consignment detention and out-of-charge refusal.
    CBIC Instruction 21/2025-Customs dated 02-07-2025
A word of counsel

The most common error on this tariff line is filing the bill of entry without the mandatory Chapter 39 additional qualifiers — a deficiency that triggers a CBIC query and delays out-of-charge even when the EPR registration is in order. The qualifiers under Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus are declaration-level obligations that cannot be rectified post-assessment without a formal amendment, and demurrage begins accruing from the date of first query.

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Frequently asked
Does HSN 3905 19 20 require BIS certification?
No, poly (vinyl acetate) polymers and resins in primary forms are not covered by any BIS Quality Control Order. Import is governed by Central Board of Indirect Taxes and Customs policy controls — specifically mandatory Chapter 39 qualifiers under CBIC Circular 23/2023-Cus and EPR portal registration verification under CBIC Instruction 21/2025-Customs.
What are the mandatory additional qualifiers required for Chapter 39 import declarations?
The qualifiers are specified in Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023, and must be included in all import declarations for commodities under Chapters 28, 29, 32, 39 and CTH 3808, with effect from 15 October 2023.
What is the EPR portal registration requirement for plastic packaging under this HSN?
Per CBIC Instruction 21/2025-Customs dated 02-07-2025, importers must verify proof of registration on the Centralised EPR Portal for Plastic Packaging and produce that proof at the bill-of-entry stage; failure to do so can result in consignment detention pending compliance.
Last verified against gazette notifications: 2026-05-16. Source: CBIC / Indian Customs CUSDATA.
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