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HomeHSNChapter 39HSN 3920 51 12

Flexible, plain

Flexible plain PMMA film, foil and strip

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 51 12 (Flexible, plain poly(methyl methacrylate) film and strip) is subject to Central Pollution Control Board (CPCB) registration and Extended Producer Responsibility (EPR) obligations under 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) and CPCB jointly administer the single-use plastic prohibition and EPR framework; CBIC mandatory chemical-qualifier declarations under CBIC Circular 15/2023-Cus apply at bill-of-entry stage.

What this is
HSN code
3920 51 12
Chapter
39 · Plastics and articles thereof
Primary regulator
CPCB · Plastic Waste Management (Amendment) Rules, 2022 — EPR registration and SUP prohibition
Customs documentation
  • EPR registration certificate from CPCB
  • IUPAC and CAS qualifier declaration from CBIC
  • ITC (HS) policy compliance from DGFT
Applicable Partner Government Agencies
CPCBCPCB·Central Pollution Control Board
MEFCCMEFCC·Ministry of Environment, Forest and Climate Change

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

Compliance steps
  1. 1
    Register on the CPCB centralised EPR portal as an importer before filing the bill of entry. Registration is mandatory under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022, and Rule 7.3 prescribes the EPR obligations that continue post-clearance; failure to register attracts detention of the consignment pending compliance.
    Rule 6 and Rule 7.3 of the Plastic Waste Management (Amendment) Rules, 2022 · G.S.R. 133(E) dated 16-02-2022 · CBIC Instruction 09/2022-Customs dated 22-06-2022
  2. 2
    Declare the IUPAC name and CAS number of all constituent chemicals in the bill of entry at the time of filing. These Chapter 39 additional qualifiers are mandatory for all 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
  3. 3
    Confirm the imported film or strip does not fall within the single-use plastic prohibition under Rule 4(2) of the Plastic Waste Management Rules (wrapping or packing films, plastic banners under 100 microns, etc.) operative from 01-07-2022, and ensure carry bags are not below 120 microns effective 31-12-2022. Also confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023), and check DGFT Notification 7/2025-26 dated 17-05-2025 for any Bangladesh-origin port restrictions under Para 19 of the General Notes.
    Rule 4(1)(c) and Rule 4(2) of the Plastic Waste Management Rules · G.S.R. 571(E) dated 12-08-2021 · G.S.R. 807(E) dated 30-10-2023 · DGFT Notification 7/2025-26 dated 17-05-2025
A word of counsel

The most common error on this tariff line is assuming that CPCB EPR registration is a one-time port formality rather than a continuing obligation tied to each import consignment. An importer registered on the CPCB portal must also fulfil annual EPR targets under Rule 7.3; a gap between registration status and EPR fulfilment can trigger retrospective scrutiny of all cleared consignments. Separately, the Chapter 39 IUPAC/CAS qualifier is verified at bill-of-entry filing — omitting it causes processing rejection before customs examination even begins.

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Frequently asked
Does HSN 3920 51 12 require BIS certification?
No. No BIS Quality Control Order covers flexible plain PMMA film or strip. Import is governed by the Central Pollution Control Board under the Plastic Waste Management (Amendment) Rules, 2022, with EPR registration and single-use plastic prohibition compliance as the operative obligations.
Which specific plastic products are prohibited from import under the SUP ban applicable to this chapter?
Rule 4(2) of the Plastic Waste Management Rules prohibits import of wrapping or packing films around sweet boxes, invitation cards and cigarette packets, plastic banners under 100 microns, and listed single-use plastic cutlery and items with effect from 01-07-2022; flexible PMMA film intended for industrial or non-SUP use is not prohibited but must be clearly distinguished from these categories at the bill of entry.
Does DGFT Notification 7/2025-26 affect imports of this product from Bangladesh?
Para 19 of the General Notes introduced by DGFT Notification 7/2025-26 dated 17-05-2025 imposes port restrictions on certain goods originating from Bangladesh; importers should verify whether this HSN falls within the regulated goods list in Para 1 and confirm applicable port eligibility before shipment.
Last verified against gazette notifications: 2026-05-16. Source: CPCB / MEFCC / DGFT / CBIC / Indian Customs CUSDATA.
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