Flexible, plain

Flexible plain film and sheet of unsaturated polyesters

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 63 20 (Flexible, plain) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration obligations under Rule 6 and Rule 9(1) of Schedule II 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) single-use plastics prohibition regime and CBIC mandatory Chapter 39 chemical-qualifier declarations apply as additional clearance requirements at the bill of entry.

What this is

HSN code

3920 63 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
Chapter 39 IUPAC/CAS qualifiers from CBIC
PWM compliance declaration to MoEFCC

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 the bill of entry. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates registration for importers of plastic packaging products, plastic sheets, or multi-layered packaging, and Rule 7.3 sets out the extended producer responsibility obligations applicable to importers.
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 as mandatory additional qualifiers in the import declaration at the time of filing the bill of entry. These Chapter 39 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
Verify the consignment does not constitute a prohibited single-use plastic item under Rule 4(2) of the Plastic Waste Management Rules, and confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023. If the consignment originates from Bangladesh, check applicability of DGFT Notification 7/2025-26 dated 17-05-2025 regarding port restrictions under Para 19 of the General Notes to ITC (HS) 2022.
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 completing FSSAI or other sectoral checks while overlooking the CPCB EPR portal registration, which is a pre-import obligation — not a post-clearance compliance step. An importer without an active CPCB registration at the time of filing the bill of entry has no lawful basis to import plastic packaging or plastic sheets regardless of whether the product itself is otherwise unrestricted, and customs out-of-charge can be withheld pending production of the registration. Additionally, the IUPAC/CAS qualifier fields in e-Sanchit are mandatory from 01-10-2023 and their absence triggers a bill of entry deficiency that stalls clearance independently of the EPR status.

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Frequently asked

Does HSN 3920 63 20 require BIS certification?

No, flexible plain sheets and film of unsaturated polyesters are not covered by any BIS Quality Control Order. Import is governed by the Central Pollution Control Board EPR registration regime under the Plastic Waste Management (Amendment) Rules, 2022, with CBIC mandatory chemical-qualifier declarations and the MoEFCC single-use plastics prohibition overlay.

Are there thickness or product-category restrictions that affect whether this film can be imported?

Yes. Rule 4(2) of the Plastic Waste Management Rules prohibits the manufacture, import, and sale of specified single-use plastic commodities with effect from 01-07-2022, and carry bags of virgin or recycled plastic must be not less than 120 microns from 31-12-2022; the specific product form must be verified against these restrictions before placing a purchase order.

Does the Bangladesh-origin port restriction under DGFT Notification 7/2025-26 apply to this HSN?

Potentially. DGFT Notification 7/2025-26 dated 17-05-2025 introduced Para 19 in the General Notes to ITC (HS) 2022, restricting the import of certain goods from Bangladesh to specified ports; importers should confirm whether this tariff line falls within the notified categories and whether the exemptions in Para 2 and Para 3 of that notification apply.

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