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HomeHSNChapter 39HSN 3920 73 22

Flexible, plain

Flexible plain cellulose acetate film, foil and sheet

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 73 22 (Flexible, plain cellulose acetate sheet, film and foil) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility registration under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 (G.S.R. 133(E) dated 16-02-2022). Directorate General of Foreign Trade (DGFT) and Central Board of Indirect Taxes and Customs (CBIC) policy overlays apply, including mandatory IUPAC name and CAS number declaration for Chapter 39 imports from 01-10-2023.

What this is
HSN code
3920 73 22
Chapter
39 · Plastics and articles thereof
Primary regulator
CPCB · Plastic Waste Management (Amendment) Rules, 2022
Customs documentation
  • EPR registration certificate 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 filing the bill of entry. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates registration of all importers of plastic packaging products or plastic sheets, and Rule 7.3 prescribes the Extended Producer Responsibility obligations that apply from the date of first import.
    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 consignment as mandatory additional qualifiers in the bill of entry at the time of filing. These qualifiers are mandatory for all bills of entry under Chapter 39 filed on or after 01-10-2023 and are in addition to existing declarations.
    CBIC Circular 15/2023-Cus dated 07-06-2023 · CBIC Circular 18/2023-Cus dated 30-06-2023
  3. 3
    Verify that the cellulose acetate film being imported does not constitute a single-use plastic commodity prohibited under Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022, and confirm compliance with any amendments introduced under the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023). If the goods originate from Bangladesh, assess applicability of DGFT Notification 7/2025-26 dated 17-05-2025 for port restrictions under Para 19 of the General Notes to ITC (HS) 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 shipment without obtaining CPCB EPR portal registration beforehand. Registration is a pre-import obligation, not a post-clearance formality — customs out-of-charge can be withheld pending evidence of CPCB registration, and an importer who has not enrolled on the centralised portal has no EPR account against which to record the consignment, exposing the entity to enforcement under the Plastic Waste Management Rules and potential Ministry of Environment, Forest and Climate Change (MEFCC) action.

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Frequently asked
Does HSN 3920 73 22 require BIS certification?
No, flexible plain cellulose acetate film and sheet falls outside the BIS Quality Control Order regime; no BIS QCO covers this product family. Import is governed by the Central Pollution Control Board under the Plastic Waste Management (Amendment) Rules, 2022, with CBIC mandatory chemical-declaration overlays.
What CPCB portal documents must be uploaded in e-Sanchit at the bill of entry for this HSN?
Evidence of CPCB EPR registration (importer category) generated on the centralised CPCB portal must be available at the bill of entry stage; Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 and CBIC Instruction 09/2022-Customs dated 22-06-2022 together require the customs proper officer to verify this registration before granting out-of-charge.
Does the prohibition on single-use plastics under Rule 4(2) affect imports of flexible cellulose acetate film under this tariff line?
The Rule 4(2) prohibition targets specified single-use plastic commodities such as wrapping films around sweet boxes and invitation cards; importers must confirm that their specific product description does not fall within those prohibited categories, and compostable plastic products are exempt under Rule 4(3).
Last verified against gazette notifications: 2026-05-16. Source: CPCB / MEFCC / DGFT / CBIC / Indian Customs CUSDATA.
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