Phenol formaldehyde resins

Phenol formaldehyde resins in primary forms

CBIC CLEARANCE

HSN 3909 40 20 (Phenol formaldehyde resins) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy overlays governing plastic packaging EPR registration and mandatory Chapter 39 import-declaration qualifiers. Importers must verify proof of registration on the Centralised EPR Portal for Plastic Packaging under CBIC Instruction 21/2025-Customs dated 02-07-2025, and comply with the mandatory additional qualifiers for Chapter 39 commodities under CBIC Circular 23/2023-Cus dated 30-09-2023.

What this is

HSN code

3909 40 20

Chapter

39 · Plastics and articles thereof

Primary regulator

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

Customs documentation

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

Compliance steps

1
Before filing the bill of entry, verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging. Non-registration at the time of import renders the consignment liable to detention pending regularisation under CBIC Instruction 21/2025-Customs dated 02-07-2025.
CBIC Instruction 21/2025-Customs dated 02-07-2025
2
Ensure the import declaration includes the mandatory additional qualifiers for Chapter 39 commodities as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus, with effect from 15-10-2023. Declarations filed without the prescribed qualifiers for phenolic resin imports are liable to rejection or reassessment at the bill of entry stage.
CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2, effective 15-10-2023

A word of counsel

The most frequent error on this tariff line is treating the Chapter 39 mandatory qualifiers as a clerical formality and omitting them on the grounds that phenol formaldehyde resins are an industrial intermediate rather than a finished plastic product. CBIC Circular 23/2023-Cus applies to all commodities under Chapter 39 without distinction between intermediates and finished goods, and a declaration filed without the prescribed qualifiers is treated as deficient — attracting reassessment, demurrage, and potential ground rent while the entry is corrected.

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Frequently asked

Does HSN 3909 40 20 require BIS certification?

No, phenol formaldehyde resins in primary forms are not covered by any BIS Quality Control Order. Import compliance is governed by Central Board of Indirect Taxes and Customs policy overlays: EPR portal registration under CBIC Instruction 21/2025-Customs and mandatory Chapter 39 declaration qualifiers under CBIC Circular 23/2023-Cus.

Do the Chapter 39 mandatory qualifiers under CBIC Circular 23/2023-Cus apply to industrial-grade phenolic resins?

Yes. Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus apply to all commodities under Chapter 39, including industrial intermediates such as phenol formaldehyde resins, with effect from 15 October 2023.

Is EPR portal registration required even if the importer is not the end-user of the plastic packaging?

CBIC Instruction 21/2025-Customs dated 02-07-2025 requires verification of proof of registration on the Centralised EPR Portal for Plastic Packaging at the point of import; the obligation attaches to the import transaction regardless of downstream end-use arrangements.

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