Alkyl phenol-formaldehyde resins

Alkyl phenol-formaldehyde resins, phenolic resins in primary forms

CBIC CLEARANCE

HSN 3909 40 30 (Alkyl phenol-formaldehyde resins) is governed by Central Board of Indirect Taxes and Customs (CBIC) policy overlays 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 and CBIC Instruction 21/2025-Customs dated 02-07-2025 as concurrent clearance conditions at the bill-of-entry stage.

What this is

HSN code

3909 40 30

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · Mandatory Chapter 39 qualifiers and EPR portal verification, CBIC Circular 23/2023-Cus

Customs documentation

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

Compliance steps

1
Include all mandatory additional qualifiers in the import declaration for Chapter 39 commodities as stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus, with effect from 15 October 2023. Missing or incomplete qualifiers will result in the bill of entry being held at assessment, causing consignment detention and demurrage.
CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2
2
Verify and submit proof of registration on the Centralised EPR Portal for Plastic Packaging before filing the bill of entry. The customs proper officer is required to verify this proof at the time of 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 with generic Chapter 39 product descriptions and overlooking the mandatory qualifiers stipulated under Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus — an omission that triggers assessment-level detention regardless of EPR compliance status. The EPR portal registration obligation under CBIC Instruction 21/2025-Customs operates independently of the qualifier requirement; satisfying one does not discharge the other, and both must be evidenced at the bill-of-entry stage.

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 40 30 require BIS certification?

No, alkyl phenol-formaldehyde resins in primary forms are not covered by any BIS Quality Control Order. Import compliance for this tariff line is governed by CBIC policy overlays — mandatory Chapter 39 qualifiers under CBIC Circular 23/2023-Cus and EPR registration verification under CBIC Instruction 21/2025-Customs.

Which specific qualifiers are mandatory for Chapter 39 import declarations under CBIC Circular 23/2023-Cus?

The mandatory additional qualifiers for commodities under Chapters 28, 29, 32, 39 and CTH 3808 are detailed in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023, applicable with effect from 15 October 2023.

Does the EPR portal registration requirement apply even when alkyl phenol-formaldehyde resin is imported as a raw material rather than finished plastic packaging?

CBIC Instruction 21/2025-Customs dated 02-07-2025 mandates verification of proof of registration on the Centralised EPR Portal for Plastic Packaging for goods under Chapter 39; importers should confirm the scope of applicability to their specific end-use with the customs proper officer at the designated port of import.

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