Flake (chip)

Polyamide-6 and related polyamide flake, chip form

CBIC CLEARANCE

HSN 3908 10 21 (Polyamide flake/chip) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy overlays governing plastic packaging EPR registration verification and mandatory Chapter 39 import-declaration qualifiers. Importers must demonstrate proof of registration on the Centralised EPR Portal for Plastic Packaging and ensure mandatory additional qualifiers are declared at the bill-of-entry stage under CBIC Circular 23/2023-Cus.

What this is

HSN code

3908 10 21

Chapter

39 · Plastics and articles thereof

Primary regulator

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

Customs documentation

EPR registration proof from CBIC portal
Chapter 39 qualifiers declaration to CBIC

Compliance steps

1
Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before filing the bill of entry. Failure to demonstrate current EPR registration triggers non-compliance under CBIC Instruction 21/2025-Customs and may result in consignment detention at the port.
CBIC Instruction 21/2025-Customs dated 02-07-2025
2
Declare mandatory additional qualifiers in the import declaration for commodities under Chapter 39 as stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus, with effect from 15 October 2023. Omission of the required qualifiers renders the bill of entry deficient and liable to rejection by the proper officer.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2, effective 15-10-2023

A word of counsel

The most common error on this tariff line is treating the Chapter 39 qualifier requirement as an administrative formality and filing the bill of entry without the complete set of additional qualifiers stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus. A declaration deficient in qualifiers stalls out-of-charge even where the EPR registration is current, because the proper officer must independently verify both obligations before granting clearance — a missing qualifier cannot be rectified retrospectively without amendment and consequential demurrage exposure.

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Frequently asked

Does HSN 3908 10 21 require BIS certification?

No, polyamide flake and chip in primary forms are not subject to any BIS Quality Control Order. Import compliance is governed by CBIC Instruction 21/2025-Customs on EPR portal registration and CBIC Circular 23/2023-Cus on mandatory Chapter 39 import-declaration qualifiers.

Which specific qualifiers are mandatory for Chapter 39 import declarations under CBIC Circular 23/2023-Cus?

The mandatory additional qualifiers for commodities under Chapter 39 are specified in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30 September 2023, applicable with effect from 15 October 2023; the importer must declare all stipulated qualifiers at the bill-of-entry stage.

Does the EPR portal registration requirement apply to polyamide flake imported for industrial use rather than consumer packaging?

CBIC Instruction 21/2025-Customs dated 02 July 2025 requires verification of proof of registration on the Centralised EPR Portal for Plastic Packaging for imports under this CTI; the regulatory record does not provide an end-use carve-out, so registration proof must be presented regardless of the intended downstream application.

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