In aqueous dispersion

Poly(vinyl acetate) dispersion in aqueous medium

CBIC CLEARANCE

HSN 3905 21 00 (Poly(vinyl acetate) in aqueous dispersion) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls governing plastic-packaging Extended Producer Responsibility (EPR) registration and mandatory Chapter 39 qualifiers in the import declaration. Importers must verify proof of registration on the Centralised EPR Portal for Plastic Packaging and ensure the bill of entry carries the additional qualifiers mandated under CBIC Circular 23/2023-Cus for Chapter 39 commodities.

What this is

HSN code

3905 21 00

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs (Chapter 39 qualifiers and EPR portal)

Customs documentation

EPR registration proof from CBIC portal
Chapter 39 qualifiers 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. Non-compliance with the EPR registration requirement renders the consignment liable to detention at the port of import.
CBIC Instruction 21/2025-Customs dated 02-07-2025
2
Include the mandatory additional qualifiers in the import declaration as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus for all commodities under Chapters 28, 29, 32 and 39. This requirement has been operative with effect from 15 October 2023.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2, w.e.f. 15-10-2023

A word of counsel

The most common error on this tariff line is filing the bill of entry without the Chapter 39 mandatory qualifiers under CBIC Circular 23/2023-Cus, which causes the declaration to be flagged for amendment or re-filing — attracting demurrage and ground rent while the consignment waits at port. The EPR portal registration is a separate, concurrent obligation; an importer holding a current registration must still produce verifiable proof at the bill-of-entry stage per CBIC Instruction 21/2025-Customs.

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Frequently asked

Does HSN 3905 21 00 require BIS certification?

No, poly(vinyl acetate) in aqueous dispersion is not within the BIS Quality Control Order regime; no BIS QCO covers this product family. Import is governed by CBIC policy controls under CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs, covering Chapter 39 qualifiers and EPR portal registration.

What are the mandatory additional qualifiers required for Chapter 39 imports under CBIC Circular 23/2023-Cus?

Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus specify the additional qualifiers required in import declarations for Chapters 28, 29, 32 and 39; the requirement has been operative from 15 October 2023 and applies to every bill of entry for this tariff line.

Does the EPR portal registration requirement apply to all importers of poly(vinyl acetate) dispersion, or only to producers of plastic packaging?

CBIC Instruction 21/2025-Customs dated 02-07-2025 requires verification of proof of registration on the Centralised EPR Portal for Plastic Packaging at the bill-of-entry stage; importers unable to produce valid proof face detention of the consignment pending compliance.

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