Other primary form

Polyamide resins in primary forms (nylon pellets, granules)

CBIC CLEARANCE

HSN 3908 10 49 (Other primary form — Polyamide-6, -11, -12, -6,6, -6,9, -6,10 or -6,12) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy overlays governing plastic-packaging EPR registration and mandatory Chapter 39 additional qualifiers in the import declaration. Importers must verify proof of registration on the Centralised EPR Portal for Plastic Packaging under CBIC Instruction 21/2025-Customs, and declare mandatory additional qualifiers in the bill of entry per CBIC Circular 23/2023-Cus.

What this is

HSN code

3908 10 49

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · Mandatory qualifier and EPR registration overlay, Chapter 39

Customs documentation

EPR registration proof from CBIC portal
Chapter 39 qualifiers from CBIC
Bill of entry declaration to CBIC

Compliance steps

1
Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before the bill of entry is filed. Customs officers are required to check this registration at the time of import clearance, and absence of valid EPR registration will result in detention of the consignment.
CBIC Instruction 21/2025-Customs dated 02-07-2025
2
Declare the mandatory additional qualifiers in the import declaration for Chapter 39 commodities as stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus with effect from 15 October 2023. Missing or incomplete qualifiers render the bill of entry non-compliant and expose the consignment to misdeclaration proceedings.
CBIC Circular 23/2023-Cus dated 30-09-2023 · Para 4.1 and 4.2

A word of counsel

The most frequent error on this tariff line is filing the bill of entry without the Chapter 39 mandatory qualifiers, treating polyamide primary-form imports as a routine chemicals declaration. CBIC Circular 23/2023-Cus mandates specific additional qualifiers for all Chapter 28, 29, 32, 39 and CTH 3808 commodities with effect from 15 October 2023; a declaration filed without these qualifiers is subject to amendment, delay, and potential misdeclaration penalties under the Customs Act, 1962.

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Frequently asked

Does HSN 3908 10 49 require BIS certification?

No, polyamide resins in primary forms fall outside the BIS Quality Control Order regime. Import compliance for this tariff line is governed by Central Board of Indirect Taxes and Customs overlays — specifically the mandatory Chapter 39 qualifier requirements under CBIC Circular 23/2023-Cus and the EPR portal registration check under CBIC Instruction 21/2025-Customs.

Which specific qualifiers must be declared for Chapter 39 imports at the bill of entry?

The mandatory additional qualifiers prescribed in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30 September 2023 apply to all Chapter 39 commodities with effect from 15 October 2023; the specific qualifier fields must be populated in the import declaration before out-of-charge.

Does the EPR registration requirement apply to all polyamide primary-form imports, including industrial-grade material not intended for consumer packaging?

CBIC Instruction 21/2025-Customs dated 02 July 2025 requires verification of EPR portal registration at import; importers should confirm the scope of their registration on the Centralised EPR Portal for Plastic Packaging against the specific end-use category of the imported polyamide to ensure the registration covers the imported form.

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