Phenoxi resins

Phenolic resins, phenoxy resins in primary forms

CBIC CLEARANCE

HSN 3909 40 50 (Phenoxy resins) is subject to customs policy controls administered by the Central Board of Indirect Taxes and Customs (CBIC), including mandatory additional qualifiers in import declarations for Chapter 39 commodities and extended producer responsibility (EPR) registration verification for plastic packaging. CBIC Circular 23/2023-Cus dated 30-09-2023 and CBIC Instruction 21/2025-Customs dated 02-07-2025 constitute the operative compliance overlay at the bill-of-entry stage.

What this is

HSN code

3909 40 50

Chapter

39 · Plastics and articles thereof

Primary regulator

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

Customs documentation

EPR registration proof from CPCB portal
Chapter 39 qualifiers from CBIC

Compliance steps

1
Include the mandatory additional qualifiers in the import declaration as stipulated in Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus with effect from 15 October 2023. These qualifiers apply to all commodities under Chapters 28, 29, 32, 39 and CTH 3808, and omission renders the bill of entry liable to rejection or reassessment.
CBIC Circular 23/2023-Cus dated 30-09-2023, Paragraphs 4.1 and 4.2
2
Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before out-of-charge. The registration requirement applies to plastic packaging imports under CBIC Instruction 21/2025-Customs and must be confirmed at the bill-of-entry stage.
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 without the Chapter 39 mandatory qualifiers, which has been a grounds for reassessment and detention since 15 October 2023. Importers who resolve the qualifier omission post-filing face demurrage and ground rent while the declaration is corrected; the EPR portal registration for plastic packaging must be live at the time of filing, not merely applied for.

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Frequently asked

Does HSN 3909 40 50 require BIS certification?

No, phenoxy resins in primary forms are not covered by any BIS Quality Control Order. The operative compliance framework is administered by the Central Board of Indirect Taxes and Customs under CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs.

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 qualifiers required in import declarations for commodities under Chapters 28, 29, 32, 39 and CTH 3808; these must be included in every bill of entry filed on or after 15 October 2023.

Does the EPR portal registration obligation apply if the phenoxy resin is imported without plastic packaging?

CBIC Instruction 21/2025-Customs dated 02-07-2025 ties the verification to proof of registration on the Centralised EPR Portal for Plastic Packaging; importers whose consignment does not constitute plastic packaging should document that position at the bill-of-entry stage to avoid detention pending verification.

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