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Other polymers of vinyl esters in primary forms

CBIC CLEARANCE

HSN 3905 19 90 (Other polymers of vinyl esters in primary forms) is subject to Central Board of Indirect Taxes and Customs (CBIC) compliance requirements, including verification of registration on the Centralized EPR Portal for Plastic Packaging under CBIC Instruction 21/2025-Customs dated 02-07-2025. Mandatory additional qualifiers in the import declaration for Chapter 39 commodities apply under CBIC Circular 23/2023-Cus dated 30-09-2023, operative from 15 October 2023.

What this is
HSN code
3905 19 90
Chapter
39 · Plastics and articles thereof
Primary regulator
CBIC · Mandatory Chapter 39 qualifiers and EPR portal registration, CBIC Circular 23/2023-Cus
Customs documentation
  • EPR portal registration proof from CBIC
  • Chapter 39 qualifiers from CBIC
Compliance steps
  1. 1
    Verify and upload proof of registration on the Centralized EPR Portal for Plastic Packaging before filing the bill of entry. Absence of valid EPR portal registration will trigger non-compliance under CBIC Instruction 21/2025-Customs dated 02-07-2025.
    CBIC Instruction 21/2025-Customs dated 02-07-2025
  2. 2
    Include all mandatory additional qualifiers in the import declaration as stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus for Chapter 39 commodities. These qualifiers have been mandatory with effect from 15 October 2023 and non-inclusion results in declaration deficiency at the bill of entry stage.
    CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2
A word of counsel

The most frequent error on this tariff line is filing the bill of entry with complete EPR registration details in hand but omitting the Chapter 39 mandatory qualifiers required under Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus — two distinct compliance obligations that must both be satisfied simultaneously. A declaration lacking the prescribed qualifiers is treated as deficient regardless of EPR compliance, exposing the consignment to detention and demurrage at port pending rectification.

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Frequently asked
Does HSN 3905 19 90 require BIS certification?
No, no BIS Quality Control Order covers polymers of vinyl esters in primary forms under this tariff line. Import compliance is governed by CBIC, principally through mandatory Chapter 39 declaration qualifiers under CBIC Circular 23/2023-Cus and EPR portal registration verification under CBIC Instruction 21/2025-Customs.
What are the mandatory qualifiers required for Chapter 39 import declarations under CBIC Circular 23/2023-Cus?
Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023 prescribe the specific additional qualifiers for commodities under Chapters 28, 29, 32, 39 and CTH 3808; these have been mandatory in import declarations from 15 October 2023 onwards.
Does the EPR portal registration requirement apply to all importers of plastic packaging materials under this HSN?
Yes. CBIC Instruction 21/2025-Customs dated 02-07-2025 requires customs officers to verify proof of registration on the Centralized EPR Portal for Plastic Packaging at the bill of entry stage for imports covered by Chapter 39.
Last verified against gazette notifications: 2026-05-16. Source: CBIC / Indian Customs CUSDATA.
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