Geomembrane, conforming to IS 16352

Polyethylene geomembranes and geomembrane lining sheets

BIS QCO APPLICABLE · ISI MARK SCHEME · IS 15351 · CPCB OVERLAY

HSN 3920 10 13 (geomembrane conforming to IS 16352) is covered by a Bureau of Indian Standards Quality Control Order. Conformity to IS 15351:2015, IS 15909:2020, or IS 16352:2020 — depending on the geomembrane substrate — is mandatory under the ISI Mark Scheme with effect from 01 October 2023, by virtue of the Plastic Films and Allied Products (Quality Control) Order notified under S.O. 1706(E). Extended Producer Responsibility registration under the Plastic Waste Management (Amendment) Rules, 2022 administered by the Central Pollution Control Board applies as a separate customs-clearance overlay.

What this is

HSN code

3920 10 13

Chapter

39 · Plastics and articles thereof

BIS QCO

Applicable · ISI Mark Scheme · CM/L required

Indian Standard

IS 15351 · effective 01-10-2023

Applicable Partner Government Agencies

BISBIS·Bureau of Indian Standards

CPCBCPCB·Central Pollution Control Board

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

Compliance steps

1
Identify the correct Indian Standard for the geomembrane substrate before sourcing: IS 15351:2015 for laminated HDPE woven geomembranes, IS 15909:2020 for PVC geomembranes, and IS 16352:2020 for HDPE geomembranes for lining. Verify that the foreign supplier holds a current BIS CM/L licence against the matching standard on the BIS online register.
S.O. 1706(E) dated 10-04-2023 · IS 15351:2015, IS 15909:2020, IS 16352:2020 as cited in CCR
2
Ensure every sheet or roll bears the ISI mark and the supplier's CM/L number in accordance with Scheme-I of Schedule-II to the BIS (Conformity Assessment) Regulations, 2018. Marking must appear on the product itself; marking on outer packaging alone does not satisfy the statutory requirement.
Scheme-I of Schedule-II to the BIS (Conformity Assessment) Regulations, 2018 · S.O. 1706(E) dated 10-04-2023
3
Register as an importer of plastic packaging on the CPCB centralised Extended Producer Responsibility portal before filing the bill of entry. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates this registration, and rule 7.3 sets the EPR obligations specific to importers.
G.S.R. 133(E) dated 16-02-2022 · G.S.R. 571(E) dated 12-08-2021 · CBIC Instruction 09/2022-Customs dated 22-06-2022
4
Declare the IUPAC name and CAS number of all constituent chemicals on the bill of entry. These additional qualifiers are mandatory for all Chapter 39 imports for bills of entry filed on or after 01 October 2023 under the Bill of Entry (Electronic Integrated Declaration and Paperless Processing) Regulations, 2018.
CBIC Circular 15/2023-CUS dated 07-06-2023 · CBIC Circular 18/2023-CUS dated 30-06-2023
5
Quote the supplier's BIS CM/L number and the CPCB EPR registration reference on the bill of entry. Ensure compliance with the Plastic Waste Management (Second Amendment) Rules, 2023. If the consignment originates in Bangladesh, verify port restrictions under DGFT Notification 7/25-26 dated 17-05-2025.
G.S.R. 807(E) dated 30-10-2023 · DGFT Notification 7/25-26 dated 17-05-2025 · BIS Act, 2016

A word of counsel

The single most common error on this tariff line is treating all geomembranes as interchangeable under a single IS number and sourcing accordingly. Three distinct Indian Standards govern this HSN — IS 15351:2015 (laminated HDPE woven), IS 15909:2020 (PVC), and IS 16352:2020 (HDPE for lining) — and a CM/L licence is standard-specific; a supplier licensed against IS 16352:2020 is not authorised to supply IS 15351:2015-compliant product. A mismatch between the substrate type declared on the bill of entry and the standard against which the CM/L is issued triggers detention and re-verification at port.

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Frequently asked

Does HSN 3920 10 13 require BIS certification?

Yes. Geomembranes under this tariff line must conform to the applicable Indian Standard — IS 15351:2015, IS 15909:2020, or IS 16352:2020 depending on substrate — and bear the ISI mark under a CM/L licence, with effect from 01 October 2023 under S.O. 1706(E).

Is Extended Producer Responsibility registration required separately from BIS QCO compliance?

Yes. EPR registration on the CPCB centralised portal is required under rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 and is independent of the BIS CM/L obligation. Rule 7.3 of those rules sets the specific EPR obligations for importers.

Which Indian Standard applies to HDPE geomembranes for pond or landfill lining?

IS 16352:2020 applies to high-density polyethylene geomembranes for lining; IS 15351:2015 applies to laminated HDPE woven geomembranes for waterproof lining; IS 15909:2020 applies to PVC geomembranes. The supplier's CM/L must match the substrate type of the consignment.

Does a single CM/L licence cover all three geomembrane types?

No. A CM/L licence is standard-specific and facility-specific; a licence against IS 16352:2020 does not authorise supply of IS 15351:2015 or IS 15909:2020 product. Each substrate type requires a separately licensed manufacturer.

Last verified against gazette notifications: 2026-05-18. Source: BIS / CPCB / DGFT / CBIC / Indian Customs CUSDATA.