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HomeHSNChapter 39HSN 3920 73 12

Flexible, plain

Flexible plain cellulose acetate film, foil or sheet

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 73 12 (Flexible, plain cellulose acetate sheet, film and foil) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration obligations 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) prohibition on specified single-use plastic items and the IUPAC name and CAS number declaration requirement under Chapter 39 administered by the Central Board of Indirect Taxes and Customs (CBIC) apply as additional clearance requirements.

What this is
HSN code
3920 73 12
Chapter
39 · Plastics and articles thereof
Primary regulator
CPCB · Plastic Waste Management (Amendment) Rules, 2022 — EPR registration regime
Customs documentation
  • EPR registration from CPCB
  • IUPAC and CAS declaration from 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. 1
    Register as an importer on the CPCB centralised EPR portal before the first bill of entry. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates registration of importers of plastic packaging products, plastic sheets, or multi-layered packaging; Rule 7.3 sets the ongoing EPR obligations once registered.
    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. 2
    Declare the IUPAC name and CAS number of each constituent chemical of the cellulose acetate film in the bill of entry at the time of filing. These additional qualifiers are mandatory for all bills of entry under Chapter 39 filed on or after 01-10-2023 and must be submitted in the format prescribed in Annex-1 to the relevant circular.
    CBIC Circular 15/2023-Cus dated 07-06-2023 · CBIC Circular 18/2023-Cus dated 30-06-2023
  3. 3
    Verify that the consignment does not fall within the single-use plastic prohibition under Rule 4(2) of the Plastic Waste Management Rules (effective 01-07-2022) or the carry-bag thickness minima under Rule 4(1)(c), and ensure compliance with any amendments introduced by the Plastic Waste Management (Second Amendment) Rules, 2023. For imports originating 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.
    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 CPCB EPR registration as a one-time formality and overlooking the annual EPR obligation targets prescribed under Rule 7.3. Registration opens the portal account; non-fulfilment of annual collection and recycling targets constitutes a continuing violation under the Plastic Waste Management Rules, and CPCB may suspend portal access, directly blocking future import clearances. Importers should also confirm at each consignment whether any new sub-category of the goods falls within an expanded single-use plastic prohibition under the Second Amendment Rules, 2023.

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Frequently asked
Does HSN 3920 73 12 require BIS certification?
No, flexible plain cellulose acetate film and sheet are outside the BIS Quality Control Order regime; no BIS QCO covers this product family. Import is governed by the Central Pollution Control Board EPR registration framework under the Plastic Waste Management (Amendment) Rules, 2022, with MoEFCC single-use plastic prohibitions and CBIC chemical-qualifier declarations as overlays.
Are the IUPAC name and CAS number declarations required even for standard commercial cellulose acetate film?
Yes. CBIC Circulars 15/2023-Cus and 18/2023-Cus make these additional qualifiers mandatory for all imports under Chapter 39 filed on or after 01-10-2023, without product-specific exemption; the declaration must follow the format in Annex-1 to those circulars.
Do the Bangladesh port restrictions under DGFT Notification 7/2025-26 apply to this HSN?
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 should verify whether this HSN falls within the listed goods or the exemptions in Para 2 and Para 3 of that notification before routing the consignment.
Last verified against gazette notifications: 2026-05-16. Source: CPCB / MEFCC / DGFT / CBIC / Indian Customs CUSDATA.
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