Cresol formaldehyde oxide

Phenolic resins, cresol formaldehyde type (primary forms)

CBIC CLEARANCE

HSN 3909 40 10 (Cresol formaldehyde oxide) is subject to Central Board of Indirect Taxes and Customs (CBIC) mandatory additional qualifiers in import declarations under Chapter 39, operative with effect from 15 October 2023 per CBIC Circular 23/2023-Cus. Importers must also verify proof of registration on the Centralised EPR Portal for Plastic Packaging as directed by CBIC Instruction 21/2025-Customs dated 02-07-2025.

What this is

HSN code

3909 40 10

Chapter

39 · Plastics and articles thereof

Primary regulator

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

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 Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus, operative with effect from 15 October 2023. Declarations lacking the required qualifiers are liable to be held pending correction at the bill of entry stage.
CBIC Circular 23/2023-Cus dated 30-09-2023, Paras 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. This requirement applies to plastic packaging associated with the imported product per 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 treating the Chapter 39 qualifier requirement as a routine labelling formality and submitting an incomplete declaration. An import declaration that omits the Paragraph 4.1 and 4.2 qualifiers triggers a hold at the bill of entry stage — not a post-clearance query — meaning the consignment cannot receive out-of-charge until the declaration is amended, accruing demurrage and ground rent at the port.

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Frequently asked

Does HSN 3909 40 10 require BIS certification?

No, cresol formaldehyde oxide (phenolic resin, primary form) falls outside the BIS Quality Control Order regime. The operative compliance framework is the CBIC mandatory qualifier requirement under Circular 23/2023-Cus for Chapter 39 commodities and the EPR portal registration requirement under CBIC Instruction 21/2025-Customs.

What are the mandatory additional qualifiers required for Chapter 39 import declarations?

The qualifiers are specified in Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023, which covers commodities under Chapters 28, 29, 32, 39 and CTH 3808; the precise fields must be populated in the import declaration with effect from 15 October 2023.

Does the EPR portal registration requirement apply to the resin itself or only to its packaging?

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 the scope of registration applicable to their specific plastic packaging format before filing the bill of entry.

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