Other

Non-cellular polyethylene film, foil and strip (PVC geomembranes)

BIS QCO APPLICABLE · ISI MARK SCHEME · IS 15909 · CPCB OVERLAY · MEFCC OVERLAY

HSN 3920 10 99 (non-cellular, unreinforced polyethylene plates, sheets, film, foil and strip) is covered by a Bureau of Indian Standards Quality Control Order. Conformity to IS 15909:2020 is mandatory under the ISI Mark Scheme with effect from 30 September 2021, by virtue of the Quality Control Order notified under S.O. 1706(E). Extended Producer Responsibility registration on the Central Pollution Control Board portal applies as a separate customs-clearance overlay under the Plastic Waste Management (Amendment) Rules, 2022.

What this is

HSN code

3920 10 99

Chapter

39 · Plastics and articles thereof

BIS QCO

Applicable · ISI Mark Scheme · CM/L required

Indian Standard

IS 15909:2020 · effective 30-09-2021

Applicable Partner Government Agencies

BISBIS·Bureau of Indian Standards

CPCBCPCB·Central Pollution Control Board

MEFCCMEFCC·Ministry of Environment, Forest and Climate Change

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

Compliance steps

1
Source only from a Bureau of Indian Standards CM/L-licensed manufacturer holding a current licence against IS 15909:2020 for PVC geomembranes. Verify the supplier's CM/L number, licensed product scope, and manufacturing facility on the BIS online register before placing the purchase order.
S.O. 1706(E) dated 10-04-2023 · Scheme-I of Schedule-II to the BIS (Conformity Assessment) Regulations, 2018
2
Ensure each product bears the ISI standard mark and the supplier's CM/L licence number in accordance with Scheme-I of Schedule-II to the BIS (Conformity Assessment) Regulations, 2018. Marking must appear on the product or its primary packaging and be traceable to the licensed batch.
S.O. 1706(E) dated 10-04-2023 · BIS (Conformity Assessment) Regulations, 2018
3
Register as an importer on the CPCB centralised portal for Extended Producer Responsibility before import. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates registration of importers of plastic packaging or plastic sheets; Rule 7.3 sets EPR obligations on importers.
G.S.R. 133(E) dated 16-02-2022 · G.S.R. 571(E) dated 12-08-2021 · G.S.R. 807(E) dated 30-10-2023 · CBIC Instruction 09/2022-Customs dated 22-06-2022
4
Declare the IUPAC name and CAS number of constituent chemicals on the bill of entry for all imports under Chapter 39 filed on or after 01-10-2023. These fields are mandatory in addition to standard declarations 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
If the consignment originates in Bangladesh, verify whether port restrictions under paragraph 19 of the general notes to the ITC (HS) 2022 import policy apply. Goods outside the documented carve-outs in paragraphs 2 and 3 are restricted to specified ports of entry.
DGFT Notification 7/25-26 dated 17-05-2025

A word of counsel

The single most common error on this residual tariff line is assuming that IS 15909:2020 covers the entire polyethylene film and sheet category. The QCO scope under S.O. 1706(E) is specifically limited to PVC geomembranes; importers of general-purpose polyethylene film and foil outside that specification who nonetheless seek a CM/L licence waste compliance spend, while importers who import genuine PVC geomembrane product and fail to check IS 15909:2020 coverage face consignment detention. Confirm with the supplier in writing whether the product meets the geomembrane specification before the purchase order.

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Frequently asked

Does HSN 3920 10 99 require BIS certification?

Yes, for PVC geomembranes falling within IS 15909:2020. Conformity is mandatory under the ISI Mark Scheme with effect from 30 September 2021 per S.O. 1706(E); import is permitted only from manufacturers holding a current BIS CM/L licence covering the relevant product specification.

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

Yes. EPR registration is administered by the Central Pollution Control Board under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 and is independent of the BIS ISI Mark Scheme obligation. Both must be in order before customs clearance.

Does IS 15909:2020 apply to all polyethylene film and sheet products classified under HSN 3920 10 99?

No. The BIS QCO under S.O. 1706(E) applies specifically to PVC geomembranes conforming to IS 15909:2020. General-purpose polyethylene film, foil, and strip not meeting the geomembrane specification are outside the IS 15909:2020 QCO scope, though they remain subject to Plastic Waste Management Rules obligations.

Does a single CM/L licence cover all geomembrane variants and manufacturing facilities?

No. A CM/L licence is scope-specific by product specification, thickness range, and licensed manufacturing facility; geomembrane variants outside the licensed specification or produced at an unlicensed plant are not covered and customs will detain the consignment on a mismatch.

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