Copolymers

Vinyl copolymers in primary forms (plastics)

CBIC CLEARANCE

HSN 3905 91 00 (Copolymers) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls requiring mandatory additional qualifiers in the import declaration under CBIC Circular 23/2023-Cus dated 30-09-2023, applicable to all commodities under Chapter 39 with effect from 15 October 2023. Extended Producer Responsibility (EPR) registration verification on the Centralised EPR Portal for Plastic Packaging is additionally required per CBIC Instruction 21/2025-Customs dated 02-07-2025.

What this is

HSN code

3905 91 00

Chapter

39 · Plastics and articles thereof

Primary regulator

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

Customs documentation

Chapter 39 qualifiers from CBIC
EPR portal registration proof from CPCB

Compliance steps

1
Include all mandatory additional qualifiers in the import declaration as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers are compulsory for all Chapter 39 commodities and the bill of entry will not be processed without them.
CBIC Circular 23/2023-Cus dated 30-09-2023, paras 4.1 and 4.2, w.e.f. 15-10-2023
2
Verify and furnish proof of registration on the Centralised EPR Portal for Plastic Packaging at the bill-of-entry stage. Customs will verify EPR portal registration status as a pre-clearance check per CBIC Instruction 21/2025-Customs.
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 Chapter 39 mandatory qualifiers, under the mistaken assumption that the qualifier requirement applies only to speciality chemicals or listed substances. Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus apply to all Chapter 39 CTIs without exception; an incomplete declaration triggers rejection at the gateway and attracts demurrage while the amended bill of entry is reprocessed. EPR portal registration must be current at the time of filing, not merely applied for.

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Frequently asked

Does HSN 3905 91 00 require BIS certification?

No, vinyl copolymers in primary forms are not covered by any BIS Quality Control Order. Import is governed by CBIC policy controls under Circular 23/2023-Cus requiring mandatory Chapter 39 declaration qualifiers, and by CBIC Instruction 21/2025-Customs requiring EPR portal registration verification.

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

Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023 specify the qualifiers; these must be declared in the import entry for all Chapter 28, 29, 32, 39 and CTH 3808 commodities with effect from 15 October 2023.

Does the EPR portal registration requirement apply to all importers of plastic packaging materials?

Yes. Per CBIC Instruction 21/2025-Customs dated 02-07-2025, proof of registration on the Centralised EPR Portal for Plastic Packaging must be verified at the bill-of-entry stage; consignments without valid registration are liable to detention pending compliance.

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