Poly(phenylene oxide)

Poly(phenylene oxide) in primary forms

CBIC CLEARANCE

HSN 3909 39 10 (Poly(phenylene oxide)) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls covering mandatory Chapter 39 additional qualifiers in import declarations and Extended Producer Responsibility (EPR) registration verification for plastic packaging. Importers must comply with CBIC Circular 23/2023-Cus dated 30-09-2023 for declaration qualifiers and CBIC Instruction 21/2025-Customs dated 02-07-2025 for EPR portal registration proof at the bill-of-entry stage.

What this is

HSN code

3909 39 10

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · Chapter 39 mandatory qualifiers and EPR portal compliance

Customs documentation

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

Compliance steps

1
File mandatory additional qualifiers in the import declaration as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus for all commodities under Chapter 39. These qualifiers have been mandatory with effect from 15 October 2023 and non-compliance results in bill-of-entry rejection.
CBIC Circular 23/2023-Cus dated 30-09-2023, para 4.1 and 4.2
2
Upload proof of registration on the Centralised EPR Portal for Plastic Packaging before out-of-charge. The CBIC Instruction 21/2025-Customs dated 02-07-2025 requires customs officers to verify this registration at the bill-of-entry stage for plastic packaging imports.
CBIC Instruction 21/2025-Customs dated 02-07-2025

A word of counsel

The most common error on this tariff line is treating it as a routine plastics import and omitting the EPR portal registration proof — the CBIC Instruction 21/2025-Customs obligation is frequently overlooked because the product is an engineering resin rather than a finished plastic packaging good. Customs officers are instructed to verify EPR registration at the bill-of-entry stage; absence of the registration proof will result in detention and demurrage while the importer remedies the gap.

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Frequently asked

Does HSN 3909 39 10 require BIS certification?

No, poly(phenylene oxide) in primary forms is not covered by any BIS Quality Control Order. Import compliance is governed by CBIC policy controls under CBIC Circular 23/2023-Cus for mandatory Chapter 39 declaration qualifiers and CBIC Instruction 21/2025-Customs for EPR portal registration verification.

What are the mandatory additional qualifiers required for Chapter 39 imports under CBIC Circular 23/2023-Cus?

Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023 specify the mandatory qualifier fields for import declarations covering commodities under Chapters 28, 29, 32, 39 and CTH 3808; these qualifiers became compulsory with effect from 15 October 2023.

Does the EPR registration requirement apply to all poly(phenylene oxide) imports or only to plastic packaging end-uses?

CBIC Instruction 21/2025-Customs dated 02-07-2025 directs verification of EPR portal registration for plastic packaging; importers should assess whether the consignment is destined for plastic packaging applications and obtain registration accordingly before filing the bill of entry.

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