Film

Regenerated cellulose film, plastic packaging EPR obligations

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 71 11 (Film of regenerated cellulose) 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 (MoEFCC) notified single-use plastic prohibitions and carry-bag thickness thresholds that apply at the import stage, and the Directorate General of Foreign Trade (DGFT) ITC (HS) policy controls apply as an additional overlay.

What this is

HSN code

3920 71 11

Chapter

39 · Plastics and articles thereof

Primary regulator

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

Customs documentation

EPR registration from CPCB
IUPAC/CAS 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. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates registration for importers of plastic packaging products or plastic sheets, and Rule 7.3 prescribes EPR obligations; failure to register renders the consignment non-compliant at the point of customs assessment.
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 in the bill of entry at the time of filing, as mandatory additional qualifiers for Chapter 39 imports. These declarations are required for all bills of entry filed on or after 01-10-2023 and are in addition to standard import declarations.
CBIC Circular 15/2023-Cus dated 07-06-2023 · CBIC Circular 18/2023-Cus dated 30-06-2023
3
Verify that the film does not fall within the single-use plastic prohibitions under Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022 — including wrapping or packing films around sweet boxes, invitation cards and cigarette packets — effective 01-07-2022. Also confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023) and, where applicable, the Bangladesh-origin port restrictions under 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 the EPR portal registration but failing to link each import transaction to the registered EPR account before the bill of entry is assessed. CPCB's centralised portal tracks importer-specific EPR targets against actual import volumes; an importer who registers but does not fulfil annual EPR targets faces liability under the Plastic Waste Management Rules, which may include monetary penalties and detention of subsequent consignments pending compliance demonstration.

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Frequently asked

Does HSN 3920 71 11 require BIS certification?

No, regenerated cellulose film is 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 centralised portal as the binding pre-import obligation.

Is regenerated cellulose film affected by the single-use plastic prohibition under Rule 4(2)?

Only if the specific product form falls within the enumerated prohibited categories — such as wrapping films around sweet boxes, invitation cards or cigarette packets — effective 01-07-2022; film for other packaging applications is not categorically prohibited but remains subject to the carry-bag thickness requirement of 120 microns from 31-12-2022.

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

They apply where the import is sourced from Bangladesh and falls within Para 19 of the General Notes of ITC (HS) 2022 as introduced by DGFT Notification 7/2025-26 dated 17-05-2025; importers should verify the exemptions listed in Paragraphs 2 and 3 of that notification before routing the consignment.

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