Flexible, plain

Flexible plain poly(vinyl butyral) film or sheet

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 91 20 (Flexible, plain poly(vinyl butyral) film and sheet) 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). Ministry of Environment, Forest and Climate Change (MoEFCC) single-use plastic prohibitions under G.S.R. 571(E) and mandatory IUPAC/CAS qualifier declarations under CBIC Circular 15/2023-Cus apply as additional clearance requirements.

What this is

HSN code

3920 91 20

Chapter

39 · Plastics and articles thereof

Primary regulator

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

Customs documentation

EPR registration from CPCB
IUPAC/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
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 for importers of plastic packaging, plastic sheets, and multilayered packaging; Rule 7.3 prescribes the corresponding EPR obligations that the registered importer must fulfil.
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-Cus 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. These additional qualifiers are mandatory for all bills of entry under Chapter 39 filed on or after 01-10-2023 under the Bill of Entry (Electronic Integrated Declaration and Paperless Processing) Regulations, 2018.
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 prohibited single-use plastic item under Rule 4(2) of the Plastic Waste Management Rules as amended by G.S.R. 571(E) dated 12-08-2021, and ensure compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023). If the goods originate from Bangladesh, verify 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 then failing to discharge the annual EPR obligations under Rule 7.3 — registration without EPR target fulfilment exposes the importer to CPCB enforcement and closure of the portal account, which blocks subsequent bills of entry. Importers also frequently overlook the IUPAC/CAS qualifier requirement for Chapter 39 goods: omission at the time of filing triggers a mismatch in the electronic declaration and can result in consignment detention pending amendment.

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Frequently asked

Does HSN 3920 91 20 require BIS certification?

No, flexible plain poly(vinyl butyral) film and sheet is not covered by any BIS Quality Control Order. Import is governed by Central Pollution Control Board EPR registration under the Plastic Waste Management (Amendment) Rules, 2022, with MoEFCC single-use plastic prohibitions and CBIC chemical-qualifier declarations as additional requirements.

Which document codes or declarations are mandatory in e-Sanchit for this tariff line?

The CBIC Circulars 15/2023-Cus and 18/2023-Cus require the IUPAC name and CAS number of constituent chemicals to be declared as mandatory qualifiers at the time of filing for all Chapter 39 bills of entry from 01-10-2023; the CPCB EPR registration credential should also be available for customs verification.

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 and, if so, route the consignment through a permitted port as stated in Para 1, noting the exemptions in Paras 2 and 3.

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