Urea formaldehyde resins

Urea formaldehyde resins in primary forms

CBIC CLEARANCE

HSN 3909 10 10 (Urea formaldehyde resins) is subject to customs-level compliance obligations administered by the Central Board of Indirect Taxes and Customs (CBIC), including mandatory Chapter 39 additional qualifiers in import declarations under CBIC Circular 23/2023-Cus dated 30-09-2023. Importers must also verify proof of registration on the Centralised EPR Portal for Plastic Packaging per CBIC Instruction 21/2025-Cus dated 02-07-2025.

What this is

HSN code

3909 10 10

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · Mandatory Chapter 39 qualifiers and EPR portal verification

Customs documentation

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

Compliance steps

1
Include all mandatory additional qualifiers in the import declaration as stipulated under paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus, applicable to commodities under Chapters 28, 29, 32, 39 and CTH 3808 with effect from 15 October 2023. Declarations lacking the prescribed qualifiers are liable to rejection at the bill-of-entry stage.
CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2
2
Verify and submit proof of registration on the Centralised EPR Portal for Plastic Packaging before filing the bill of entry. Failure to furnish valid EPR portal registration proof attracts non-clearance under CBIC Instruction 21/2025-Cus.
CBIC Instruction 21/2025-Cus dated 02-07-2025

A word of counsel

The most common error on this tariff line is treating the Chapter 39 qualifier obligation as a post-clearance administrative formality rather than a bill-of-entry prerequisite. Declarations filed without the mandatory qualifiers are returned for amendment, triggering demurrage and ground rent at the port. Separately, the EPR portal registration requirement under CBIC Instruction 21/2025-Cus is a distinct verification step — an importer holding all standard trade documents but lacking a current EPR registration will face consignment detention.

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Frequently asked

Does HSN 3909 10 10 require BIS certification?

No, urea formaldehyde resins in primary forms are not covered by any BIS Quality Control Order. Import compliance is governed by CBIC-level obligations: mandatory Chapter 39 qualifiers under CBIC Circular 23/2023-Cus and EPR portal registration verification under CBIC Instruction 21/2025-Cus.

What qualifiers are mandatory in the import declaration for Chapter 39 commodities?

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

Does the EPR portal registration requirement apply to all importers of plastic packaging materials including resins?

Yes. CBIC Instruction 21/2025-Cus dated 02-07-2025 requires verification of proof of registration on the Centralised EPR Portal for Plastic Packaging at the bill-of-entry stage for consignments falling within the scope of that instruction.

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