Other
Phenolic resins in primary forms, other types
HSN 3909 40 90 (Phenolic resins, Other) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy overlays governing import declarations and extended producer responsibility compliance. Mandatory additional qualifiers under CBIC Circular 23/2023-Cus apply to all import declarations for Chapter 39 commodities, and verification of EPR portal registration for plastic packaging applies under CBIC Instruction 21/2025-Cus.
- Chapter 39 qualifiers from CBIC
- EPR portal registration proof from CBIC
- 1Include all mandatory additional qualifiers in the import declaration as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus, applicable to commodities under Chapters 28, 29, 32, 39 and CTH 3808 with effect from 15 October 2023. Declarations filed without these qualifiers are liable to rejection at the bill of entry stage.CBIC Circular 23/2023-Cus dated 30-09-2023, Para 4.1 and 4.2
- 2Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before filing the bill of entry. CBIC Instruction 21/2025-Cus mandates that customs officers verify this registration for plastic packaging commodities, including phenolic resins in primary forms.CBIC Instruction 21/2025-Cus dated 02-07-2025
The most common error on this tariff line is filing the bill of entry with product description alone and omitting the Chapter 39 mandatory qualifiers required under CBIC Circular 23/2023-Cus paragraphs 4.1 and 4.2. A declaration deficient in these qualifiers is flagged at the system level and can result in consignment detention and demurrage while the amended declaration is processed. The EPR portal registration requirement under Instruction 21/2025-Cus is a separate and concurrent obligation that applies independently of the declaration-qualifier compliance.