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HomeHSNChapter 39HSN 3908 10 39

Other primary form

Polyamide-6, -11, -12 and variants in other primary forms

CBIC CLEARANCE

HSN 3908 10 39 (polyamide resins in other primary forms) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy overlays governing Chapter 39 plastic imports, including mandatory additional qualifiers in import declarations under CBIC Circular 23/2023-Cus dated 30-09-2023 and Extended Producer Responsibility (EPR) portal registration verification under CBIC Instruction 21/2025-Customs dated 02-07-2025. Both requirements attach at the bill-of-entry stage and must be satisfied before out-of-charge.

What this is
HSN code
3908 10 39
Chapter
39 · Plastics and articles thereof
Primary regulator
CBIC · Chapter 39 mandatory qualifiers and EPR portal compliance, CBIC Circular 23/2023-Cus and Instruction 21/2025-Customs
Customs documentation
  • EPR portal registration proof from CBIC
  • Chapter 39 qualifiers declaration from CBIC
Compliance steps
  1. 1
    Ensure the importer holds valid registration on the Centralised EPR Portal for Plastic Packaging and upload proof of registration at the bill-of-entry stage. Customs officers are directed to verify this registration before granting out-of-charge under CBIC Instruction 21/2025-Customs.
    CBIC Instruction 21/2025-Customs dated 02-07-2025
  2. 2
    Include all 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. These qualifiers have been mandatory with effect from 15 October 2023 and non-compliant declarations attract examination and detention.
    CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2, w.e.f. 15-10-2023
A word of counsel

The most common error on this tariff line is submitting the bill of entry with the Chapter 39 qualifiers populated but omitting the EPR portal registration proof — these are two independent CBIC requirements and each is checked separately at the out-of-charge stage. A consignment that clears the qualifier check but lacks EPR registration verification will be detained pending documentary compliance, accruing demurrage and ground rent while the registration is obtained or uploaded.

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Frequently asked
Does HSN 3908 10 39 require BIS certification?
No, polyamide resins in primary forms are not covered by any BIS Quality Control Order. Import is governed by Central Board of Indirect Taxes and Customs policy overlays — mandatory Chapter 39 declaration qualifiers under CBIC Circular 23/2023-Cus and EPR portal registration verification under CBIC Instruction 21/2025-Customs.
What are the mandatory qualifiers required in the import declaration for Chapter 39 commodities?
The qualifiers are prescribed in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023 and have been mandatory with effect from 15 October 2023 for all import declarations covering commodities under Chapters 28, 29, 32, 39 and CTH 3808.
Does the EPR registration requirement apply to all importers of polyamide in primary forms?
Yes. CBIC Instruction 21/2025-Customs dated 02-07-2025 directs verification of proof of registration on the Centralised EPR Portal for Plastic Packaging for imports of plastic packaging material, and customs officers are required to confirm this before granting out-of-charge.
Last verified against gazette notifications: 2026-05-16. Source: CBIC / Indian Customs CUSDATA.
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