Moulding powders

Cellulose nitrate moulding powders in primary forms

CBIC CLEARANCE

HSN 3912 20 21 (Cellulose nitrate moulding powders) is subject to Central Board of Indirect Taxes and Customs (CBIC) mandatory additional qualifier requirements under CBIC Circular 23/2023-Cus dated 30-09-2023 for Chapter 39 commodities. Extended Producer Responsibility (EPR) registration on the Centralised EPR Portal for Plastic Packaging must also be verified at the bill of entry per CBIC Instruction 21/2025-Customs dated 02-07-2025.

What this is

HSN code

3912 20 21

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · Mandatory Chapter 39 qualifiers and EPR portal registration, CBIC Circular 23/2023-Cus

Customs documentation

EPR registration proof from Centralised EPR Portal
Chapter 39 qualifiers from CBIC

Compliance steps

1
Ensure the import declaration includes all mandatory additional qualifiers for Chapter 39 commodities as stipulated in paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus. These qualifiers are compulsory with effect from 15-10-2023 and absent or incomplete qualifiers will result in bill of entry rejection.
CBIC Circular 23/2023-Cus dated 30-09-2023, paragraphs 4.1 and 4.2
2
Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before seeking out-of-charge. The customs officer must confirm EPR registration compliance at the bill of entry stage per CBIC Instruction 21/2025-Customs.
CBIC Instruction 21/2025-Customs dated 02-07-2025

A word of counsel

The most common error on this tariff line is submitting the bill of entry with the Chapter 39 mandatory qualifiers populated but without the EPR portal registration proof — these are two independent CBIC obligations and failure on either triggers separate enforcement action. The EPR obligation applies to importers of plastic packaging regardless of end-use, and cellulose nitrate moulding powders imported in packaging that falls within the EPR scope are not exempt simply because the product itself is a chemical intermediate.

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Frequently asked

Does HSN 3912 20 21 require BIS certification?

No, cellulose nitrate moulding powders are not covered by any BIS Quality Control Order. Import compliance is governed by CBIC under Circular 23/2023-Cus for mandatory Chapter 39 qualifiers and CBIC Instruction 21/2025-Customs for EPR portal registration verification.

From which date are the mandatory Chapter 39 qualifiers compulsory, and what happens if they are missing?

The mandatory additional qualifiers for Chapter 39 commodities are compulsory with effect from 15 October 2023 per paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus; a bill of entry filed without them is liable to rejection at the customs gateway.

Does the EPR registration requirement apply even when the importer is not the end-use manufacturer?

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 import stage, irrespective of the importer's downstream role.

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