Flexible, plain

Flexible plain PMMA film, foil and strip

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 51 92 (Flexible, plain poly(methyl methacrylate) film) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility registration and compliance 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) single-use plastic prohibitions under Rule 4(2) of those Rules apply at the bill of entry stage, and Directorate General of Foreign Trade (DGFT) policy controls and CBIC chemical-qualifier requirements constitute additional customs overlays.

What this is

HSN code

3920 51 92

Chapter

39 · Plastics and articles thereof

Primary regulator

CPCB · Plastic Waste Management (Amendment) Rules, 2022 — EPR registration and importer obligations

Customs documentation

EPR registration certificate from CPCB
IUPAC name and CAS number declaration to 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
Register as an importer on the CPCB centralised EPR portal before filing any bill of entry for plastic packaging or plastic sheet products. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates this registration, and Rule 7.3 prescribes ongoing Extended Producer Responsibility obligations for importers; non-registration renders the consignment liable to detention.
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
Declare the IUPAC name and CAS number of each constituent chemical at the time of filing the import declaration in e-Sanchit. These additional qualifiers are mandatory for all bills of entry under Chapter 39 filed on or after 01-10-2023 per 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
Verify the consignment does not fall within the single-use plastic prohibition under Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022, effective 01-07-2022, and confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023. Where the goods are routed through Bangladesh, assess applicability of DGFT Notification 7/2025-26 dated 17-05-2025 regarding port restrictions under Para 19 of the General Notes of the ITC (HS) 2022.
Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022 · 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 completing CPCB portal registration but failing to update EPR obligations following the Second Amendment Rules notified vide G.S.R. 807(E) dated 30-10-2023 — the 2022 registration does not automatically carry forward the updated compliance framework. Separately, importers importing thin wrapping or packing film variants within this HSN must positively confirm the product is not a prohibited single-use plastic commodity under Rule 4(2), since customs officers treat the prohibition as an absolute bar and will confiscate non-compliant goods regardless of whether the EPR registration is current.

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Frequently asked

Does HSN 3920 51 92 require BIS certification?

No, flexible plain PMMA film and strip are not covered by any BIS Quality Control Order. Import is governed by the Central Pollution Control Board under the Plastic Waste Management (Amendment) Rules, 2022, with EPR registration on the CPCB portal as the primary compliance obligation.

Are the IUPAC name and CAS number declarations mandatory even for standard commercial PMMA film shipments?

Yes. Per CBIC Circulars 15/2023-CUS and 18/2023-CUS, the IUPAC name and CAS number of constituent chemicals are mandatory additional qualifiers for all Chapter 39 bills of entry filed on or after 01-10-2023, without exception for product type or commercial grade.

Does the single-use plastic prohibition under Rule 4(2) apply to flexible PMMA film used as wrapping film for commercial goods?

Rule 4(2), effective 01-07-2022, expressly prohibits wrapping or packing films around sweet boxes, invitation cards and cigarette packets; the carve-out under Rule 4(3) applies only to commodities made of compostable plastic, so non-compostable PMMA wrapping film falling within the prohibited categories is barred from import.

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