Polyacrylonitrile (PAN)

Polyacrylonitrile in primary forms

CBIC CLEARANCE

HSN 3906 90 50 (Polyacrylonitrile) 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. Importers must also demonstrate 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 90 50

Chapter

39 · Plastics and articles thereof

Primary regulator

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

Customs documentation

EPR portal registration proof from CBIC
Chapter 39 qualifiers from CBIC

Compliance steps

1
Include the mandatory additional qualifiers in the import declaration for Chapter 39 commodities as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers have been mandatory with effect from 15 October 2023 and their absence renders the bill of entry incomplete.
CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2
2
Obtain and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before the bill of entry is assessed. Failure to demonstrate valid EPR registration triggers CBIC verification and potential detention of the consignment.
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 them as optional supplementary data. Since 15 October 2023, absent qualifiers under paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus constitute a deficient import declaration, exposing the consignment to assessment delay and ground rent liability. The EPR portal registration requirement under CBIC Instruction 21/2025-Customs adds a second independent compliance gate that must be cleared simultaneously.

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Frequently asked

Does HSN 3906 90 50 require BIS certification?

No, no BIS Quality Control Order covers polyacrylonitrile in primary forms. Import compliance is governed by the Central Board of Indirect Taxes and Customs under CBIC Circular 23/2023-Cus for mandatory Chapter 39 declaration qualifiers and CBIC Instruction 21/2025-Customs for EPR portal registration.

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

The qualifiers are prescribed in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023, applicable to Chapters 28, 29, 32, 39 and CTH 3808, and are mandatory with effect from 15 October 2023.

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

Yes. CBIC Instruction 21/2025-Customs dated 02-07-2025 requires verification of proof of registration on the Centralised EPR Portal for Plastic Packaging, and customs officers are directed to confirm this at the bill of entry stage before granting out-of-charge.

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