Other

Other amino-resins in primary forms (melamine, urea, thiourea resins)

CBIC CLEARANCE

HSN 3909 39 90 (Other amino-resins in primary forms) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy overlays, including mandatory additional qualifiers in import declarations under CBIC Circular 23/2023-Cus and Extended Producer Responsibility (EPR) registration verification under CBIC Instruction 21/2025-Customs. No sectoral PGA licence is required, but both overlays are verified at the bill-of-entry stage and non-compliance triggers out-of-charge denial.

What this is

HSN code

3909 39 90

Chapter

39 · Plastics and articles thereof

Primary regulator

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

Customs documentation

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

Compliance steps

1
Include all 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 bills of entry covering CTH 3909 39 90.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2
2
Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before filing the bill of entry. The customs proper officer will check this registration as directed under CBIC Instruction 21/2025-Customs dated 02-07-2025; absence of valid EPR registration prevents out-of-charge.
CBIC Instruction 21/2025-Customs dated 02-07-2025

A word of counsel

The most common error on this tariff line is filing a bill of entry with complete commercial documentation but omitting the Chapter 39 mandatory qualifiers required by CBIC Circular 23/2023-Cus. Declarations lacking the stipulated qualifiers in paragraphs 4.1 and 4.2 are flagged at assessment, triggering queries and detention even where the EPR registration is current; both requirements are independent and must be satisfied simultaneously at the bill-of-entry stage.

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Frequently asked

Does HSN 3909 39 90 require BIS certification?

No, no BIS Quality Control Order covers amino-resins in primary forms under this tariff line. Import is governed by Central Board of Indirect Taxes and Customs policy overlays — specifically the mandatory Chapter 39 qualifiers under CBIC Circular 23/2023-Cus and EPR portal registration verification under CBIC Instruction 21/2025-Customs.

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

The qualifiers are specified 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, and are mandatory in all import declarations with effect from 15 October 2023.

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

Yes. CBIC Instruction 21/2025-Customs dated 02-07-2025 requires customs officers to verify proof of registration on the Centralised EPR Portal for Plastic Packaging for consignments under Chapter 39; importers without valid registration face denial of out-of-charge at the bill-of-entry stage.

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