Other

Non-cellular polyester film, foil and strip of other polyesters

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 69 39 (other non-cellular, unreinforced polyester film, foil and strip) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration under Rule 6 and Rule 9(1) 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 plastic prohibitions under Rule 4(2) of the Plastic Waste Management Rules apply concurrently, with CBIC mandatory chemical-qualifier declarations required at bill-of-entry filing under CBIC Circular 15/2023-Cus and 18/2023-Cus.

What this is

HSN code

3920 69 39

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 importer registration; Rule 7.3 prescribes ongoing EPR obligations including annual return filings. Failure to register constitutes a violation under the Environment (Protection) Act, 1986 and attracts penalty and consignment 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 Chapter 39 chemical qualifiers are mandatory for all bills of entry filed on or after 01-10-2023 and are required in addition to existing declarations; non-declaration results in the bill of entry being held for amendment before out-of-charge.
CBIC Circular 15/2023-Cus dated 07-06-2023 · CBIC Circular 18/2023-Cus dated 30-06-2023
3
Verify that the goods do not fall within the single-use plastic prohibition under Rule 4(2) of the Plastic Waste Management Rules — specifically wrapping or packing films prohibited from 01-07-2022 — and confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023). Where the consignment originates from Bangladesh, check applicability of port restrictions under Para 19 of the General Notes to ITC (HS) 2022 per DGFT Notification 7/2025-26 dated 17-05-2025.
Rule 4(2) of the Plastic Waste Management Rules · 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 treating CPCB EPR registration as a post-import administrative step rather than a pre-filing prerequisite. Customs out-of-charge is contingent on verified EPR registration status; an importer who ships first and registers later faces consignment detention, accumulating demurrage and ground rent, with no rectification pathway at port. The Second Amendment Rules (G.S.R. 807(E) dated 30-10-2023) introduced updated EPR target thresholds that differ from the 2022 base rules — ensure the registration reflects the current obligations, not the original 2022 schedule.

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Frequently asked

Does HSN 3920 69 39 require BIS certification?

No. No BIS Quality Control Order covers non-cellular unreinforced polyester film, foil and strip under this tariff line. Import is governed by the Central Pollution Control Board under the Plastic Waste Management (Amendment) Rules, 2022, with MoEFCC single-use plastic prohibitions and CBIC chemical-qualifier declarations as concurrent obligations.

Which specific plastic film products are prohibited from import under the single-use plastic rules?

Rule 4(2) of the Plastic Waste Management Rules prohibits, with effect from 01-07-2022, wrapping or packing films around sweet boxes, invitation cards and cigarette packets, among other listed single-use plastic commodities; the prohibition does not apply to commodities made of compostable plastic per Rule 4(3).

Do the Bangladesh port restrictions under DGFT Notification 7/2025-26 apply to polyester film imports?

Para 19 of the General Notes to ITC (HS) 2022, introduced by DGFT Notification 7/2025-26 dated 17-05-2025, imposes port restrictions on certain goods imported from Bangladesh; importers must verify whether this HSN falls within the regulated goods list under Para 1 or qualifies for an exemption under Paras 2 and 3.

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