Flexible, plain
Flexible plain polypropylene film, foil or sheet
HSN 3920 20 20 (Flexible, plain polypropylene film) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration and obligations for importers under Rule 6 and Rule 7.3 of the Plastic Waste Management (Amendment) Rules, 2022 (G.S.R. 133(E) dated 16-02-2022). The Ministry of Environment, Forest and Climate Change (MoEFCC) prohibits the import of specified single-use plastic items with effect from 01-07-2022, and CBIC chemical-qualifier declarations under Chapters 28, 29, 32, 38 and 39 are mandatory at the bill-of-entry stage from 01-10-2023.
- EPR registration from CPCB
- IUPAC/CAS qualifier declaration to CBIC
- Single-use plastic compliance certificate from importer
Procedural directions for customs clearance are issued by: Directorate General of Foreign Trade, Central Board of Indirect Taxes and Customs.
- 1Register as an importer on the CPCB centralised EPR portal before the first bill of entry is filed. Importers of plastic packaging products, carry bags, multi-layered packaging or plastic sheets are mandatorily required to register under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022, and to fulfil EPR obligations prescribed under Rule 7.3.Rule 6 and Rule 7.3, Plastic Waste Management (Amendment) Rules, 2022 · G.S.R. 133(E) dated 16-02-2022 · CBIC Instruction 09/2022-Customs dated 22-06-2022
- 2Declare the IUPAC name and CAS number of all constituent chemicals in the bill of entry at the time of filing. These additional qualifiers are mandatory for all Chapter 39 imports on bills of entry filed on or after 01-10-2023 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
- 3Verify that the polypropylene film being imported does not fall within the single-use plastic prohibition under Rule 4(2) of the Plastic Waste Management Rules (e.g., wrapping or packing films around sweet boxes, invitation cards and cigarette packets). Confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023) and, where the goods originate in Bangladesh, check port restrictions under DGFT Notification 7/2025-26 dated 17-05-2025.Rule 4(2), Plastic Waste Management Rules as amended · G.S.R. 807(E) dated 30-10-2023 · DGFT Notification 7/2025-26 dated 17-05-2025
The most common error on this tariff line is registering on the CPCB EPR portal after filing the first bill of entry, rather than before. Registration is a pre-condition to import, not a post-clearance formality; a consignment where the importer is unregistered at the time of filing is liable to detention pending regularisation, and CPCB has no provision for retrospective EPR registration prior to the bill-of-entry date. Simultaneously, importers who secure EPR registration sometimes overlook the CBIC chemical-qualifier obligation — an incomplete IUPAC/CAS declaration triggers out-of-charge hold under Customs Circular 15/2023-Cus independently of the CPCB clearance.