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HomeHSNChapter 39HSN 3912 39 11

Ethylcellulose

Ethylcellulose in primary forms

FSSAI CLEARANCE

HSN 3912 39 11 (Ethylcellulose) is subject to Food Safety and Standards Authority of India (FSSAI) Import Licence requirements under the Food Safety and Standards Act, 2006, with a specimen copy of label mandatory at the bill-of-entry stage. Centralised EPR Portal registration for plastic packaging is required under CBIC Instruction 21/2025-Customs dated 02-07-2025, and mandatory Chapter 39 additional qualifiers in the import declaration apply from 15 October 2023 under CBIC Circular 23/2023-Customs.

What this is
HSN code
3912 39 11
Chapter
39 · Plastics and articles thereof
Primary regulator
FSSAI · Food Safety and Standards Act, 2006
Customs documentation
  • Import Licence from FSSAI
  • Specimen copy of label from FSSAI
  • EPR registration proof from CBIC portal
Applicable Partner Government Agencies
FSSAIFSSAI·Food Safety and Standards Authority of India

Procedural directions for customs clearance are issued by: Directorate General of Foreign Trade, Central Board of Indirect Taxes and Customs.

Compliance steps
  1. 1
    Obtain an FSSAI Import Licence and ensure both the licence (document code 911001) and the specimen copy of label (document code 0110FS) are uploaded in e-Sanchit before filing the bill of entry. No out-of-charge may be granted until both documents are verified in e-Sanchit by the proper officer.
    CBIC Instruction 09/2023-Cus dated 07-03-2023 · CBIC Instruction 10/2022-Cus dated 28-06-2022 · FSSAI order dated 18-11-2022 under F.No.Import/TFM/Apex/2022-FSSAI
  2. 2
    Verify and upload proof of registration on the Centralised EPR Portal for Plastic Packaging before the bill of entry is assessed. Non-compliance with the EPR registration requirement constitutes a standalone customs contravention independent of the FSSAI clearance.
    CBIC Instruction 21/2025-Customs dated 02-07-2025
  3. 3
    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-Customs, operative from 15 October 2023. Route the consignment through a designated food-import entry point in compliance with General Note 4(D) of Schedule I of the ITC (HS) 2022.
    CBIC Circular 23/2023-Customs dated 30-09-2023 · General Note 4(D) of Schedule I of ITC (HS) 2022
A word of counsel

The most common error on this tariff line is treating ethylcellulose solely as a Chapter 39 chemical and overlooking the FSSAI food-import overlay, which applies because the substance is used as a food-grade coating and encapsulation agent. An importer who files without the FSSAI Import Licence and specimen copy of label uploaded in e-Sanchit will face detention at the designated food-import entry point; the EPR plastic-packaging registration is a separate, concurrent requirement that does not substitute for — and is not waived by — FSSAI clearance.

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Frequently asked
Does HSN 3912 39 11 require BIS certification?
No, ethylcellulose in primary forms is not covered by any BIS Quality Control Order. Import is governed by the Food Safety and Standards Authority of India under the Food Safety and Standards Act, 2006, with concurrent CBIC-administered EPR and Chapter 39 declaration requirements.
Which document codes must be uploaded in e-Sanchit for this tariff line?
The FSSAI Import Licence (document code 911001) and the specimen copy of label (document code 0110FS) must both be uploaded in e-Sanchit; the proper officer is required to verify these before granting out-of-charge, per CBIC Instruction 09/2023-Cus dated 07-03-2023.
Can labelling deficiencies be rectified at the port for imported ethylcellulose consignments?
Yes, subject to the conditions in CBIC Instruction 10/2022-Cus and the FSSAI rectifiable-labelling regime: permitted deficiencies may be corrected by affixing a single non-detachable sticker next to the principal display panel at a customs-bonded warehouse before inspection, without altering original label information.
Last verified against gazette notifications: 2026-05-16. Source: FSSAI / DGFT / CBIC / Indian Customs CUSDATA.
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