Other

Other petroleum resins, polysulphides, polysulphones in primary forms

CBIC CLEARANCE

HSN 3911 90 90 (Other plastics in primary forms under Chapter 39) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy overlays governing Extended Producer Responsibility (EPR) registration and mandatory Chapter 39 chemical qualifiers in import declarations. Importers must demonstrate proof of registration on the Centralised EPR Portal for Plastic Packaging under CBIC Instruction 21/2025-Customs dated 02-07-2025, and must supply mandatory additional qualifiers in the bill of entry per CBIC Circular 23/2023-Cus dated 30-09-2023.

What this is

HSN code

3911 90 90

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs (Chapter 39 qualifiers and EPR portal registration)

Customs documentation

EPR portal registration proof from CBIC
Chapter 39 mandatory qualifiers from CBIC

Compliance steps

1
Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before filing the bill of entry. Customs clearance (out-of-charge) is contingent on this verification per CBIC Instruction 21/2025-Customs.
CBIC Instruction 21/2025-Customs dated 02-07-2025
2
Include mandatory additional qualifiers in the import declaration for Chapter 39 commodities as stipulated in Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus. This requirement is operative with effect from 15 October 2023 and applies to all CTIs under Chapters 28, 29, 32, 39 and CTH 3808.
CBIC Circular 23/2023-Cus dated 30-09-2023 · Para 4.1 and 4.2

A word of counsel

The most common error on this tariff line is filing the bill of entry with a valid EPR registration but omitting the Chapter 39 mandatory qualifiers required under CBIC Circular 23/2023-Cus Para 4.1 and 4.2 — or conversely, supplying the qualifiers while failing to upload the EPR portal registration proof. Both are independent obligations: a deficiency in either triggers consignment detention and potential demurrage at port pending rectification.

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Frequently asked

Does HSN 3911 90 90 require BIS certification?

No, this residual Chapter 39 tariff line is not covered by any BIS Quality Control Order. Import compliance is governed by Central Board of Indirect Taxes and Customs policy overlays: EPR portal registration under CBIC Instruction 21/2025-Customs and mandatory Chapter 39 import-declaration qualifiers under CBIC Circular 23/2023-Cus.

When did the mandatory Chapter 39 qualifier requirement come into effect?

The requirement under Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus applies with effect from 15 October 2023 to all import declarations covering commodities under Chapters 28, 29, 32, 39 and CTH 3808, including HSN 3911 90 90.

Does the EPR portal registration obligation apply to all importers of plastic packaging under this HSN?

Yes. CBIC Instruction 21/2025-Customs dated 02-07-2025 requires verification of proof of registration on the Centralised EPR Portal for Plastic Packaging at the bill-of-entry stage; importers without current registration face clearance refusal.

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