Flake (chip)

Polyamide-6 flake (chip) in primary forms

CBIC CLEARANCE

HSN 3908 10 71 (Polyamide-6 flake/chip) 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 import declarations. Proof of registration on the Centralised EPR Portal for Plastic Packaging must be verified at the bill of entry, and mandatory additional qualifiers under CBIC Circular 23/2023-Cus are required for all Chapter 39 commodity import declarations with effect from 15 October 2023.

What this is

HSN code

3908 10 71

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 CBIC portal
Chapter 39 qualifiers from CBIC

Compliance steps

1
Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before filing the bill of entry. Non-compliance with the EPR registration requirement attracts detention of the consignment under 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 Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers have been compulsory for all Chapter 39 import declarations with effect from 15 October 2023.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2

A word of counsel

The most common error on this tariff line is filing the bill of entry with correct classification and duty payment but omitting the mandatory Chapter 39 qualifiers required under CBIC Circular 23/2023-Cus — an omission that triggers a customs query and delays out-of-charge regardless of whether the EPR documentation is in order. Both the qualifier compliance and the EPR registration proof are independently verified; a consignment complete on one count but deficient on the other remains detained until both are satisfied.

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Frequently asked

Does HSN 3908 10 71 require BIS certification?

No, polyamide-6 flake (chip) in primary forms is not covered by any BIS Quality Control Order. Import is governed by Central Board of Indirect Taxes and Customs policy overlays, specifically the EPR registration requirement under CBIC Instruction 21/2025-Customs and the mandatory Chapter 39 declaration qualifiers under CBIC Circular 23/2023-Cus.

When did the mandatory additional qualifiers for Chapter 39 import declarations become effective?

The mandatory additional qualifiers stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus became effective from 15 October 2023 and apply to all import declarations for commodities under Chapters 28, 29, 32 and 39, including CTH 3808.

Does the EPR portal registration requirement apply to imports of raw polymer chip or only to finished plastic packaging?

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 import stage; the regulatory record does not carve out raw polymer chip from this requirement, so registration proof must be presented at the bill of entry.

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