Polyurethanes

Polyurethanes in primary forms

CBIC CLEARANCE

HSN 3909 50 00 (Polyurethanes) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy controls requiring mandatory additional qualifiers in import declarations under CBIC Circular 23/2023-Cus dated 30-09-2023, operative from 15 October 2023 for commodities under Chapter 39. Importers must also verify proof of registration on the centralised Extended Producer Responsibility (EPR) portal for plastic packaging under CBIC Instruction 21/2025-Customs dated 02-07-2025.

What this is

HSN code

3909 50 00

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · Chapter 39 mandatory qualifiers and EPR portal compliance

Customs documentation

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

Compliance steps

1
Include all mandatory additional qualifiers in the import declaration as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers are compulsory for all commodities under Chapters 28, 29, 32, 39 and CTH 3808, with effect from 15 October 2023; an incomplete declaration will result in customs detention at the bill-of-entry stage.
CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2
2
Obtain and upload proof of registration on the centralised EPR portal for plastic packaging before the bill of entry is filed. The proper officer will verify this proof before granting out-of-charge under the CBIC instruction on EPR compliance.
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 in the import declaration — a deficiency that triggers mandatory customs examination and delays out-of-charge regardless of whether the goods themselves are otherwise compliant. The EPR portal registration is a separate and concurrent requirement; holding one without the other is treated as non-compliance, and there is no post-arrival remedy that avoids demurrage.

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Frequently asked

Does HSN 3909 50 00 require BIS certification?

No, polyurethanes in primary forms are not covered by any BIS Quality Control Order. Import is governed by Central Board of Indirect Taxes and Customs policy controls — specifically the mandatory declaration qualifiers under CBIC Circular 23/2023-Cus and the EPR portal registration requirement under CBIC Instruction 21/2025-Customs.

Which specific qualifiers are required in the import declaration for Chapter 39 commodities?

The mandatory additional qualifiers are detailed 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 polyurethane importers or only to those dealing in plastic packaging?

CBIC Instruction 21/2025-Customs dated 02-07-2025 requires verification of EPR portal registration for plastic packaging; importers should confirm at the time of filing whether their polyurethane product falls within the plastic packaging scope, as non-applicability must be documented to avoid out-of-charge delay.

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