Bis (polyoxyethylene) methylphosphonate

Bis(polyoxyethylene) methylphosphonate, polyether flame retardant

MEFCC CLEARANCE

HSN 3907 21 00 (Bis(polyoxyethylene) methylphosphonate) is subject to Ministry of Environment, Forest and Climate Change (MEFCC) oversight under the Centralized EPR Portal for Plastic Packaging, with compliance verified per CBIC Instruction 21/2025-Customs dated 02-07-2025. The product also carries a Chemical Weapons Convention (CWC) dual-use overlay as a Category 1B phosphonate compound, requiring post-import notification to the National Authority, CWC, and DGFT within 30 days. Import is Free under the ITC (HS) policy administered by the Directorate General of Foreign Trade (DGFT), subject to those controls.

What this is

HSN code

3907 21 00

Chapter

39 · Plastics and articles thereof

Primary regulator

MEFCC · Centralized EPR Portal for Plastic Packaging (CBIC Instruction 21/2025-Customs)

Customs documentation

EPR registration proof from MEFCC
Chapter 39 mandatory qualifiers from CBIC
CWC notification acknowledgement from DGFT

Applicable Partner Government Agencies

MEFCCMEFCC·Ministry of Environment, Forest and Climate Change

Procedural directions for customs clearance are issued by: Directorate General of Foreign Trade, Central Board of Indirect Taxes and Customs.

Compliance steps

1
Verify and upload proof of registration on the Centralized EPR Portal for Plastic Packaging before filing the bill of entry. Customs will cross-check EPR registration status against the portal as required under CBIC Instruction 21/2025-Customs dated 02-07-2025.
CBIC Instruction 21/2025-Customs dated 02-07-2025
2
Declare the mandatory additional qualifiers in the import declaration for commodities under Chapter 39, as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023, with effect from 15-10-2023. Non-declaration or incorrect qualifiers attract bill-of-entry rejection and potential detention.
CBIC Circular 23/2023-Cus dated 30-09-2023, paras 4.1 and 4.2
3
As a Category 1B CWC-scheduled phosphonate, notify import details within 30 days of each consignment to the National Authority CWC (Cabinet Secretariat), Ministry of External Affairs (D&ISA), Department of Chemicals and Petrochemicals, and DGFT, and submit a copy of the bill of entry to DGFT within the same window. Imports are permitted only from State Parties to the CWC.
CWC Act and Rules · ITC (HS) Appendix-II, Policy Condition 3 of Chapter 29 · DGFT Notification 54/2015-20 dated 09-02-2022

A word of counsel

The most common error on this tariff line is treating the ITC (HS) 'Free' status as meaning unrestricted import. The CWC Category 1B dual-use classification imposes a hard country-of-origin constraint — supply only from CWC State Parties is lawful — and the 30-day post-import notification obligation runs from the date of each importation independently of any annual or batch compliance cycle. Missing the notification window is a standalone CWC Rules violation distinct from the Customs Act position, and pre-blended polyol containing HCFC-141b remains absolutely prohibited under the Ozone Depleting Substances (Regulation and Control) Amendment Rules, 2014, regardless of the primary product's Free status.

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Frequently asked

Does HSN 3907 21 00 require BIS certification?

No, this product family falls outside the BIS Quality Control Order regime; no BIS QCO covers polyether phosphonates under Chapter 39. Import is governed by the Ministry of Environment, Forest and Climate Change EPR portal registration requirement and the CWC dual-use notification obligation administered by DGFT.

What are the Chapter 39 mandatory qualifiers required at the bill-of-entry stage?

CBIC Circular 23/2023-Cus dated 30-09-2023 mandates specific additional qualifiers in import declarations for Chapter 39 commodities, operative from 15 October 2023; the precise qualifier fields are set out in paragraphs 4.1 and 4.2 of that circular and must be populated before out-of-charge.

Is import of pre-blended polyol containing HCFC-141b permitted under this tariff line?

No. Import of pre-blended polyol containing Group VI ozone-depleting substances, including HCFC-141b, is not permitted under the Ozone Depleting Substances (Regulation and Control) Amendment Rules, 2014, as reaffirmed by DGFT Notification 54/2015-20 dated 09-02-2022.

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