Flake (chip)

Polyamide-6 and related polyamide flake, chip form

CBIC CLEARANCE

HSN 3908 10 61 (Polyamide flake/chip) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls, including mandatory verification of Extended Producer Responsibility (EPR) registration on the Centralised EPR Portal for Plastic Packaging under CBIC Instruction 21/2025-Customs dated 02-07-2025. Chapter 39 mandatory additional qualifiers in import declarations are required at the bill-of-entry stage under CBIC Circular 23/2023-Cus dated 30-09-2023.

What this is

HSN code

3908 10 61

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs

Customs documentation

EPR registration proof from Centralised EPR Portal
Chapter 39 qualifiers declaration to CBIC

Compliance steps

1
Before filing the bill of entry, verify and obtain proof of registration on the Centralised EPR Portal for Plastic Packaging. Upload the registration proof in e-Sanchit and ensure the customs declaration reflects current EPR compliance status as required by CBIC Instruction 21/2025-Customs.
CBIC Instruction 21/2025-Customs dated 02-07-2025
2
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. This requirement is operative with effect from 15 October 2023 and applies to all import entries for CTH 3908.
CBIC Circular 23/2023-Cus dated 30-09-2023, paras 4.1 and 4.2

A word of counsel

The most common error on this tariff line is filing the bill of entry with complete commercial documentation but without the Chapter 39 mandatory qualifiers, treating the declaration as a standard polymer import. Since 15 October 2023, absence of the qualifiers specified in paras 4.1 and 4.2 of CBIC Circular 23/2023-Cus is itself a ground for customs query and detention, independent of EPR compliance; both obligations must be addressed before out-of-charge.

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Frequently asked

Does HSN 3908 10 61 require BIS certification?

No, polyamide flake in primary forms falls outside the BIS Quality Control Order regime; no BIS QCO covers this product family. Import is governed by CBIC policy controls under CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs, covering EPR portal registration and mandatory declaration qualifiers.

What are the mandatory qualifiers required at the bill of entry for Chapter 39 imports?

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

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

Yes. CBIC Instruction 21/2025-Customs dated 02-07-2025 requires verification of proof of registration on the Centralised EPR Portal for Plastic Packaging at the time of import, and the customs proper officer checks for this before granting out-of-charge.

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