Terpene phenolic resins

Terpene phenolic resins in primary forms

CBIC CLEARANCE

HSN 3909 40 60 (Terpene phenolic resins) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy overlays governing import declarations for Chapter 39 commodities. Mandatory additional qualifiers in the import declaration are required under CBIC Circular 23/2023-Cus dated 30-09-2023, with effect from 15 October 2023. Extended Producer Responsibility (EPR) registration verification on the centralised EPR portal for plastic packaging applies under CBIC Instruction 21/2025-Customs dated 02-07-2025.

What this is

HSN code

3909 40 60

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · ITC (HS) policy overlays, Chapter 39; 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 Chapter 39 commodities as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers have been mandatory with effect from 15 October 2023 and must be accurately reflected in the bill of entry at the time of filing.
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. Customs will verify EPR registration compliance per CBIC Instruction 21/2025-Customs; consignments without confirmed EPR registration proof are liable to detention.
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 incomplete Chapter 39 qualifiers — treating the mandatory-qualifier requirement as a post-clearance administrative step rather than a pre-filing obligation. An import declaration missing the qualifiers stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus is non-compliant from the moment of filing and attracts reassessment, demurrage, and potential monetary penalty under the Customs Act, 1962.

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Frequently asked

Does HSN 3909 40 60 require BIS certification?

No. Terpene phenolic resins are not covered by any BIS Quality Control Order. Import is governed by Central Board of Indirect Taxes and Customs policy overlays — specifically the mandatory Chapter 39 declaration qualifiers under CBIC Circular 23/2023-Cus and EPR portal registration verification under CBIC Instruction 21/2025-Customs.

What are the mandatory qualifiers required in the import declaration for this HSN?

The qualifiers are stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023, applicable to all commodities under Chapters 28, 29, 32, 39 and CTH 3808, with effect from 15 October 2023.

Does the EPR portal registration requirement apply to all importers of terpene phenolic resins?

Yes, per CBIC Instruction 21/2025-Customs dated 02-07-2025, proof of registration on the centralised EPR portal for plastic packaging must be verified at the bill-of-entry stage; failure to produce proof exposes the consignment to detention pending verification.

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