Flexible, plain

Flexible plain polycarbonate film, sheet or foil

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 61 20 (Flexible, plain polycarbonate sheet/film) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 (G.S.R. 133(E) dated 16-02-2022). The Directorate General of Foreign Trade (DGFT) and Central Board of Indirect Taxes and Customs (CBIC) apply overlapping policy controls, including mandatory IUPAC name and CAS number qualifiers at bill-of-entry filing for Chapter 39 imports and, where applicable, Bangladesh-origin port restrictions under DGFT Notification 7/2025-26.

What this is

HSN code

3920 61 20

Chapter

39 · Plastics and articles thereof

Primary regulator

CPCB · Plastic Waste Management (Amendment) Rules, 2022 (EPR registration regime)

Customs documentation

EPR registration certificate from CPCB
IUPAC and CAS qualifiers from CBIC
ITC (HS) policy declaration 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 centralised CPCB portal before the first consignment is filed. Registration is mandatory under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022, and Rule 7.3 prescribes the EPR obligations — including reporting obligations — of importers of plastic packaging products.
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
At the bill-of-entry stage, declare the IUPAC name and CAS number of the constituent chemicals for all Chapter 39 imports. These 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-Customs dated 07-06-2023 · CBIC Circular 18/2023-Customs dated 30-06-2023
3
Confirm the consignment does not constitute a prohibited single-use plastic item under Rule 4(2) of the Plastic Waste Management Rules (prohibited with effect from 01-07-2022), and ensure compliance with the Plastic Waste Management (Second Amendment) Rules, 2023. For Bangladesh-origin consignments, verify applicable port restrictions under DGFT Notification 7/2025-26 dated 17-05-2025, Para 19.
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 frequent error on this tariff line is completing the CPCB portal registration only after the first bill of entry is filed — courts and adjudicating authorities have treated this as a prior-registration obligation, not a post-import one, exposing importers to consignment detention and monetary penalty under the Environment (Protection) Act, 1986. Separately, the mandatory IUPAC/CAS qualifier fields added by CBIC Circular 15/2023-Customs are distinct from the EPR obligations and are verified by the customs system at the time of electronic filing; an incomplete declaration causes an automatic bill-of-entry hold that no PGA clearance can override.

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Frequently asked

Does HSN 3920 61 20 require BIS certification?

No. No BIS Quality Control Order covers flexible plain polycarbonate film or sheet. Import is governed by the Central Pollution Control Board EPR registration regime under the Plastic Waste Management (Amendment) Rules, 2022, with CBIC Chapter 39 chemical-qualifier obligations and DGFT policy controls as overlays.

Which specific plastic products are prohibited from import under Rule 4(2) of the Plastic Waste Management Rules?

Rule 4(2) prohibits, with effect from 01-07-2022, items including plates, cups, glasses, cutlery, straws, trays, wrapping or packing films around sweet boxes and invitation cards, plastic or PVC banners below 100 microns, and stirrers; the prohibition does not extend to compostable plastic equivalents under Rule 4(3).

Do Bangladesh-origin consignments of this HSN face additional restrictions?

Yes, where Para 19 of DGFT Notification 7/2025-26 dated 17-05-2025 applies, Bangladesh-origin imports are subject to specified port restrictions; Paras 2 and 3 of that notification set out the exempted goods categories that should be checked before shipment.

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