Other

Cellulose nitrates (collodions) in primary forms, other

CBIC CLEARANCE

HSN 3912 20 29 (Cellulose nitrates — other) is subject to Central Board of Indirect Taxes and Customs (CBIC) policy overlays governing plastic-packaging EPR registration verification and mandatory Chapter 39 additional qualifiers in import declarations. Importers must demonstrate proof of registration on the Centralised EPR Portal for Plastic Packaging and file mandatory additional qualifiers under CBIC Circular 23/2023-Cus with effect from 15 October 2023.

What this is

HSN code

3912 20 29

Chapter

39 · Plastics and articles thereof

Primary regulator

CBIC · CBIC Circular 23/2023-Cus and CBIC Instruction 21/2025-Customs

Customs documentation

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

Compliance steps

1
Verify that the importer holds valid registration on the Centralised EPR Portal for Plastic Packaging and upload proof of that registration before filing the bill of entry. Absence of valid EPR registration triggers non-compliance under CBIC Instruction 21/2025-Customs dated 02-07-2025.
CBIC Instruction 21/2025-Customs dated 02-07-2025
2
Include all 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. This requirement has been operative with effect from 15 October 2023 and applies to every bill of entry covering CTH 3912 20 29.
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 filing the bill of entry without the Chapter 39 mandatory qualifiers, treating the additional-qualifier requirement as a downstream compliance step rather than a gate at assessment. An import declaration for CTH 3912 20 29 submitted without the Paragraph 4.1 and 4.2 qualifiers is liable to reassessment and detention; the EPR-portal registration check under CBIC Instruction 21/2025-Customs is a separate, concurrent verification that the proper officer performs at the bill-of-entry stage.

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Frequently asked

Does HSN 3912 20 29 require BIS certification?

No, cellulose nitrates in primary forms are not covered by any BIS Quality Control Order. Import is governed by CBIC policy overlays — specifically the mandatory additional-qualifier regime under CBIC Circular 23/2023-Cus and the Centralised EPR Portal for Plastic Packaging registration requirement under CBIC Instruction 21/2025-Customs.

What are the mandatory additional qualifiers required for Chapter 39 import declarations?

The qualifiers are stipulated in Paragraphs 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30-09-2023, operative from 15 October 2023, and must be included in every import declaration covering commodities under Chapters 28, 29, 32, 39 and CTH 3808.

Does the EPR portal registration requirement apply to all importers of cellulose nitrates?

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 valid registration are not in compliance regardless of whether the product itself is used as plastic packaging.

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