Binders for pigments or inks

Acrylic polymer binders for pigments or inks

CBIC CLEARANCE

HSN 3906 10 10 (Binders for pigments or inks) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls, including mandatory additional qualifiers in import declarations for Chapter 39 commodities under CBIC Circular 23/2023-Cus dated 30-09-2023, effective 15 October 2023. Importers must also verify proof of registration on the Centralised EPR Portal for Plastic Packaging under CBIC Instruction 21/2025-Customs dated 02-07-2025.

What this is

HSN code

3906 10 10

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · Mandatory Chapter 39 qualifiers and EPR portal registration, CBIC Circular 23/2023-Cus

Customs documentation

Chapter 39 qualifiers from CBIC
EPR portal registration proof from CBIC

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 for commodities under Chapters 28, 29, 32, 39 and CTH 3808. Non-compliance from 15 October 2023 onwards renders the bill of entry deficient and liable to detention pending correction.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2
2
Verify and produce proof of registration on the Centralised EPR Portal for Plastic Packaging before out-of-charge. The customs proper officer is required to check this registration proof at the bill-of-entry stage 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 — treating the declaration as a standard polymer import and overlooking Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. A declaration missing the stipulated qualifiers is flagged at the assessment stage, causing consignment detention and demurrage while an amended declaration is processed; the EPR portal registration proof is an independent requirement and its absence is a separate ground for withholding out-of-charge.

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Frequently asked

Does HSN 3906 10 10 require BIS certification?

No, acrylic polymer binders for pigments or inks are not covered by any BIS Quality Control Order. Import is governed by CBIC policy controls under CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs, requiring mandatory Chapter 39 qualifiers and EPR portal registration proof.

What are the mandatory qualifiers required in the import declaration for Chapter 39 commodities?

The qualifiers are specified in Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023, which apply to commodities under Chapters 28, 29, 32, 39 and CTH 3808, with effect from 15 October 2023.

Does the EPR portal registration requirement apply to all importers of this HSN?

Yes. 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, and absence of this proof is an independent ground for withholding customs out-of-charge.

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