Flexible, plain

Flexible plain polyester film, foil and strip

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 69 12 (Flexible, plain polyester film/foil/strip) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration 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 (MoEF&CC) prohibition on specified single-use plastic items and the 75-micron/120-micron thickness floor for carry bags apply concurrently, alongside CBIC Chapter 39 chemical-qualifier declarations and Directorate General of Foreign Trade (DGFT) import-policy overlays.

What this is

HSN code

3920 69 12

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 on the CPCB centralised EPR portal as an importer of plastic packaging before filing the bill of entry. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates this registration, and Rule 7.3 prescribes the ongoing EPR obligations; absence of registration renders the import unlawful and may attract seizure and penalty under the Environment (Protection) Act, 1986.
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 are mandatory additional qualifiers for all Chapter 39 bills of entry filed on or after 01-10-2023. Failure to include these fields causes e-Sanchit processing rejection at the bill-of-entry stage.
CBIC Circular 15/2023-CUS dated 07-06-2023 · CBIC Circular 18/2023-CUS dated 30-06-23 · Bill of Entry (Electronic Integrated Declaration and Paperless Processing) Regulations, 2018
3
Verify that the imported film/foil/strip does not constitute a prohibited single-use plastic item under Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022, and confirm compliance with any changes introduced by the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023). If sourcing from Bangladesh, confirm applicability of the port restrictions under Para 19 of the ITC (HS) General Notes per DGFT Notification 7/2025-26 dated 17-05-2025.
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 EPR registration but failing to fulfil the annual EPR target obligations under Rule 7.3 — registration alone does not discharge the importer's extended producer responsibility. A registered importer that misses its plastic-waste processing targets faces suspension of the EPR certificate, which in turn invalidates the compliance basis for subsequent bills of entry and triggers detention. Separately, importers of carry-bag-adjacent flexible film must confirm thickness compliance (75 microns from 30-09-2021; 120 microns from 31-12-2022) before the purchase order is placed, as a thickness-deficient consignment is subject to outright confiscation with no remediation pathway at port.

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Frequently asked

Does HSN 3920 69 12 require BIS certification?

No, flexible plain polyester film and foil are not within the BIS Quality Control Order regime. Import is governed by Central Pollution Control Board EPR registration obligations under the Plastic Waste Management (Amendment) Rules, 2022, with concurrent MoEF&CC prohibition and CBIC chemical-qualifier declaration requirements.

Are the IUPAC name and CAS number declarations mandatory at bill of entry for this HSN?

Yes. Per CBIC Circulars 15/2023-CUS and 18/2023-CUS, these additional qualifiers are mandatory for all Chapter 39 import declarations filed on or after 01-10-2023 and must be entered at the time of filing, not retrospectively.

Do the Bangladesh import port restrictions under DGFT Notification 7/2025-26 apply to this tariff line?

Potentially yes. Para 19 introduced into the ITC (HS) 2022 General Notes by DGFT Notification 7/2025-26 dated 17-05-2025 restricts the import of certain goods from Bangladesh to specified ports; importers sourcing from Bangladesh must verify whether this tariff line falls within the listed goods and, if so, route accordingly.

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