Poly(methylene phenyl isocyanate) (crude MDI, polymeric MDI)

Poly(methylene phenyl isocyanate), crude MDI, polymeric MDI

CBIC CLEARANCE

HSN 3909 31 00 (Poly(methylene phenyl isocyanate) — crude MDI, polymeric MDI) is subject to Central Board of Indirect Taxes and Customs (CBIC) compliance obligations, including mandatory additional qualifiers in the import declaration for Chapter 39 commodities 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-Customs dated 02-07-2025.

What this is

HSN code

3909 31 00

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · Circular 23/2023-Cus and Instruction 21/2025-Customs, Chapter 39 mandatory qualifiers and EPR portal registration

Customs documentation

Chapter 39 qualifiers from CBIC
EPR portal registration proof from CBIC

Compliance steps

1
Include all mandatory additional qualifiers in the import declaration for this Chapter 39 commodity as stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus. The requirement has been in force with effect from 15 October 2023 and applies to all bills of entry covering Chapters 28, 29, 32, 39 and CTH 3808.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2, effective 15-10-2023
2
Verify and produce proof of registration on the Centralised EPR Portal for Plastic Packaging before the bill of entry is processed. Failure to furnish valid EPR portal registration proof will prevent out-of-charge clearance under CBIC Instruction 21/2025-Customs.
CBIC Instruction 21/2025-Customs dated 02-07-2025

A word of counsel

The most common error on this tariff line is filing the bill of entry without the Chapter 39 mandatory qualifiers, treating them as optional supplementary data rather than conditions precedent to out-of-charge. An incomplete qualifier field triggers a CBIC flag and detains the consignment pending amendment, accruing demurrage and ground rent. The EPR portal registration obligation under Instruction 21/2025-Customs is a separate and concurrent requirement — satisfying the qualifier rule does not discharge the EPR registration check.

Need a regulatory steer on this product?

Speak to a regulatory counsel about your specific HSN, IS, and supplier situation.

Speak to an Expert

Frequently asked

Does HSN 3909 31 00 require BIS certification?

No, poly(methylene phenyl isocyanate) is not covered by any BIS Quality Control Order. The operative requirements are CBIC Circular 23/2023-Cus mandatory qualifiers for Chapter 39 import declarations and proof of EPR portal registration under CBIC Instruction 21/2025-Customs.

What are the mandatory additional qualifiers required under CBIC Circular 23/2023-Cus for this HSN?

Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023 specify the qualifier fields for Chapter 39 commodities; the requirement has been mandatory since 15 October 2023 and must be included in every import declaration filed for this tariff line.

Does the EPR portal registration requirement apply to all importers of crude MDI or only to certain categories?

CBIC Instruction 21/2025-Customs dated 02-07-2025 requires verification of proof of registration on the Centralised EPR Portal for Plastic Packaging; importers should confirm their registration status on the portal before filing the bill of entry to avoid detention.

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