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HomeHSNChapter 39HSN 3911 20 00

Poly (1,3-phenylene methylphosphonate)

Poly (1,3-phenylene methylphosphonate) in primary forms

DGFT CLEARANCE · CBIC CLEARANCE

HSN 3911 20 00 (Poly (1,3-phenylene methylphosphonate)) is subject to the ITC (HS) import policy administered by the Directorate General of Foreign Trade (DGFT), restricted to imports from State Parties to the Chemical Weapons Convention (CWC) under policy condition 3 of Chapter 29 of the ITC (HS). The Central Board of Indirect Taxes and Customs (CBIC) mandates additional Chapter 39 qualifiers in the import declaration and EPR portal registration compliance as concurrent customs-clearance obligations.

What this is
HSN code
3911 20 00
Chapter
39 · Plastics and articles thereof
Primary regulator
DGFT · ITC (HS) Restricted import policy, CWC policy condition 3, Chapter 29
Customs documentation
  • CWC notification declaration to DGFT
  • Bill of entry copy to DGFT
  • Chapter 39 qualifiers from CBIC
Compliance steps
  1. 1
    Confirm the exporting country is a State Party to the Chemical Weapons Convention before placing the purchase order. For each import consignment, notify — within 30 days of import — the consignment details to the National Authority CWC (Cabinet Secretariat), Ministry of External Affairs (D&ISA), Department of Chemicals and Petrochemicals, and DGFT, and submit a copy of the bill of entry to DGFT within the same 30-day window.
    CWC Act and Rules · ITC (HS) policy condition 3 of Chapter 29 · Appendix-II of ITC (HS) Import Policy
  2. 2
    Ensure the importer or their producer holds a valid registration on the Centralized EPR Portal for Plastic Packaging and that proof of registration is verifiable at the bill-of-entry stage in accordance with CBIC Instructions 21/2025-Customs dated 02-07-2025.
    CBIC Instruction 21/2025-Customs dated 02-07-2025
  3. 3
    Submit 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 dated 30-09-2023, operative with effect from 15 October 2023. Non-compliance results in the bill of entry being held pending re-submission.
    CBIC Circular 23/2023-Cus dated 30-09-2023, paras 4.1 and 4.2
A word of counsel

The most common error on this tariff line is treating the 30-day CWC post-import notification as a back-office formality rather than a binding legal obligation enforceable under the CWC Act and Rules. Failure to notify all four designated authorities — National Authority CWC, MEA (D&ISA), Department of Chemicals and Petrochemicals, and DGFT — within 30 days of each consignment, or failure to submit the bill of entry copy to DGFT within the same window, constitutes a separate breach of policy condition 3 of Chapter 29 and exposes the importer to enforcement action independent of customs clearance.

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Frequently asked
Does HSN 3911 20 00 require BIS certification?
No. No BIS Quality Control Order covers poly (1,3-phenylene methylphosphonate). Import is governed by the ITC (HS) Restricted import policy administered by the Directorate General of Foreign Trade, with CWC-origin restrictions under policy condition 3 of Chapter 29 and CBIC mandatory-qualifier obligations under Circular 23/2023-Cus.
Is the 30-day CWC notification requirement triggered on every consignment?
Yes. Per Appendix-II of the ITC (HS) import policy and policy condition 3 of Chapter 29, the importer must notify the four designated authorities and submit the bill of entry to DGFT within 30 days of each and every import, with no annual or consolidated reporting exemption.
Does the EPR portal registration requirement apply even if the imported polymer is used as a raw material rather than sold as plastic packaging?
CBIC Instruction 21/2025-Customs dated 02-07-2025 requires verification of EPR portal registration proof at the bill-of-entry stage for Chapter 39 commodities; importers should confirm the scope of the EPR obligation with respect to their specific downstream use to avoid consignment detention pending verification.
Last verified against gazette notifications: 2026-05-16. Source: DGFT / CBIC / Indian Customs CUSDATA.
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