Plain

Plain regenerated cellulose film, foil and strip

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 71 21 (Plain regenerated cellulose film) is subject to the Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration and compliance obligations under Rule 6 and Rule 7.3 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 prohibition under Rule 4(2) of the Plastic Waste Management Rules applies as a concurrent restriction, and CBIC Instruction 09/2022-Customs dated 22-06-2022 governs customs-level verification of these requirements.

What this is

HSN code

3920 71 21

Chapter

39 · Plastics and articles thereof

Primary regulator

CPCB · Plastic Waste Management (Amendment) Rules, 2022 (G.S.R. 133(E))

Customs documentation

EPR registration certificate from CPCB
IUPAC and CAS number declaration to CBIC
Import 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 on the centralised CPCB 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 ongoing EPR obligations; unregistered importers are in contravention of G.S.R. 133(E) dated 16-02-2022.
Rule 6 and Rule 7.3, 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 Chapter 39 qualifiers. This declaration is required under CBIC Circular 15/2023-CUS dated 07-06-2023 and 18/2023-CUS dated 30-06-2023 for all bills of entry filed on or after 01-10-2023.
CBIC Circular 15/2023-CUS dated 07-06-2023; CBIC Circular 18/2023-CUS dated 30-06-2023
3
Confirm the consignment does not constitute a Single-Use Plastic commodity prohibited under Rule 4(2) of the Plastic Waste Management Rules (effective 01-07-2022) and verify conformance with the Plastic Waste Management (Second Amendment) Rules, 2023 notified vide G.S.R. 807(E) dated 30-10-2023. Where imports originate from Bangladesh, verify applicability of port restrictions under Para 19 of DGFT Notification 7/2025-26 dated 17-05-2025.
Rule 4(2), 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 completing the CPCB EPR registration once at onboarding and assuming it covers all subsequent import consignments without tracking the annual EPR target obligations prescribed under Rule 7.3 — shortfalls in EPR fulfilment constitute a continuing contravention, not a one-time lapse, and can trigger consignment detention at the next bill of entry. Separately, the IUPAC/CAS declaration under CBIC Circular 15/2023-CUS is a mandatory field at the time of filing; a bill of entry submitted without it is liable to rejection prior to out-of-charge.

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Frequently asked

Does HSN 3920 71 21 require BIS certification?

No, plain regenerated cellulose film does not fall within the BIS Quality Control Order regime. Import is governed by the Central Pollution Control Board under the Plastic Waste Management (Amendment) Rules, 2022, with MoEFCC Single-Use Plastic restrictions and CBIC chemical-declaration overlays applying concurrently.

Which specific documents must be uploaded in e-Sanchit for this tariff line?

The CPCB EPR registration certificate and the IUPAC/CAS number declaration are mandatory at the bill of entry stage; the proper officer verifies these under CBIC Instruction 09/2022-Customs before granting out-of-charge.

Do the Single-Use Plastic prohibitions under Rule 4(2) apply to plain regenerated cellulose film used as wrapping film?

Wrapping or packing films are among the prohibited Single-Use Plastic commodities listed under Rule 4(2)(b) effective 01-07-2022; however, Rule 4(3) carves out commodities made of compostable plastic, so conformance with the compostable-plastic definition in the Rules must be documented if that exemption is claimed.

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