Hardened proteins (such as hardened casein, gelatin)

Hardened proteins in primary forms (hardened casein, gelatin)

FSSAI CLEARANCE

HSN 3913 90 20 (Hardened proteins such as hardened casein and gelatin) is subject to Food Safety and Standards Authority of India (FSSAI) Import Licence and labelling compliance under the Food Safety and Standards Act, 2006. Directorate General of Foreign Trade (DGFT) ITC (HS) policy conditions including designated food-import entry points under General Note 4(D) apply as additional clearance requirements. A Central Board of Indirect Taxes and Customs (CBIC) EPR-portal registration verification and mandatory Chapter 39 additional qualifiers in the import declaration are operative from 15 October 2023.

What this is

HSN code

3913 90 20

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
Chapter 39 qualifiers from CBIC

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
Obtain the FSSAI Import Licence and ensure the Specimen Copy of Label is current and FSS (Labelling and Display) Regulations, 2020 compliant before shipment. Both documents — FSSAI Import Licence (document code 911001) and Specimen Copy of Label (document code 0110FS) — must be uploaded in e-Sanchit before the bill of entry is granted out-of-charge.
CBIC Instruction 10/2022-Customs dated 28-06-2022 · CBIC Instruction 09/2023-Cus dated 07-03-2023 · FSSAI order dated 18-11-2022 under F.No.Import/TFM/Apex/2022-FSSAI
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, operative with effect from 15 October 2023. Declarations filed without the required Chapter 39 qualifiers are liable to detention at assessment.
CBIC Circular 23/2023-Cus dated 30-09-2023
3
Verify that the exporting manufacturer is registered on the Centralised EPR Portal for Plastic Packaging and produce proof of such registration at the bill of entry stage, in compliance with CBIC Instruction 21/2025-Customs. Route the consignment only through a designated food-import entry point as required under General Note 4(D) of Schedule I of the ITC (HS) 2022.
CBIC Instruction 21/2025-Customs dated 02-07-2025 · General Note 4(D) of Schedule I, ITC (HS) 2022

A word of counsel

The most common error on this tariff line is overlooking the EPR-portal registration requirement, treating it as a plastics-packaging obligation irrelevant to a food-ingredient product. Hardened proteins classified under Chapter 39 fall squarely within the CBIC Instruction 21/2025-Customs verification scope; a consignment lacking proof of EPR registration will be held at the customs examination stage even when the FSSAI Import Licence and label documents are in order. The Chapter 39 additional-qualifiers obligation under CBIC Circular 23/2023-Cus is a separate and concurrent requirement that cannot be remedied post-filing.

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Frequently asked

Does HSN 3913 90 20 require BIS certification?

No, hardened proteins are not within the BIS Quality Control Order regime; no BIS QCO covers this product family. Import is governed by the Food Safety and Standards Authority of India under the Food Safety and Standards Act, 2006, with CBIC-administered EPR and Chapter 39 qualifier overlays.

Are labelling deficiencies on imported hardened protein consignments rectifiable at port?

Yes, specified labelling deficiencies — including per-serve percentage contribution to recommended dietary allowance and date of expiry alongside best-before date — may be rectified at customs bonded warehouses by affixing a single non-detachable sticker, subject to the conditions in CBIC Instruction 10/2022-Customs and FSSAI order dated 18-11-2022. Rectification must be completed before visual inspection by the authorised FSSAI officer.

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

Para 4.1 and 4.2 of CBIC Circular 23/2023-Cus dated 30 September 2023 prescribe the mandatory additional qualifiers for commodities under Chapters 28, 29, 32, 39 and CTH 3808; they are operative from 15 October 2023 and must appear in the import declaration at the time of filing.

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