Skip to main content
Access IndiaPLATFORM
HomeHSNChapter 39HSN 3920 91 90

Other

Poly (vinyl butyral) plastic sheets, film, foil and strip

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 91 90 (Other poly (vinyl butyral) plastic film, foil, and strip) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration under Rule 6 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 Directorate General of Foreign Trade (DGFT) ITC (HS) import policy apply as additional overlays. CBIC mandatory chemical-qualifier declarations under Circular 15/2023-Cus and 18/2023-Cus are required at the bill-of-entry stage.

What this is
HSN code
3920 91 90
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/CAS qualifier declaration to CBIC
  • Single-use plastic compliance from MoEFCC
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 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, carry bags, and multi-layered packaging; Rule 7.3 prescribes EPR obligations that must be discharged on an ongoing basis.
    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 as mandatory qualifiers at the time of filing the import declaration. These fields are required for all bills of entry under Chapter 39 filed on or after 01-10-2023 and must be provided in the format specified in Annex-1 to the relevant CBIC circulars.
    CBIC Circular 15/2023-Cus dated 07-06-2023 · CBIC Circular 18/2023-Cus dated 30-06-2023
  3. 3
    Verify the consignment does not constitute a prohibited single-use plastic item under Rule 4(2) of the Plastic Waste Management Rules (prohibition effective 01-07-2022), and confirm carry-bag thickness compliance: minimum 75 microns from 30-09-2021 and 120 microns from 31-12-2022 per Rule 4(1)(c). Also confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023). Where the consignment originates from Bangladesh, assess applicability of DGFT Notification 7/2025-26 dated 17-05-2025 regarding port restrictions under Para 19 of the General Notes of ITC (HS) 2022.
    Rule 4(1)(c) and Rule 4(2) of the Plastic Waste Management Rules · 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 treating EPR registration as a post-import administrative formality. CPCB registration must be active before the bill of entry is filed; an unregistered importer cannot demonstrate EPR compliance at the out-of-charge stage, and consignment detention follows. Separately, the IUPAC/CAS chemical-qualifier declaration is mandatory under Chapter 39 and cannot be omitted even where the importer regards the plastic formulation as commercially standard — absence of these qualifiers triggers a bill-of-entry deficiency flag that delays out-of-charge independently of EPR status.

Need a regulatory steer on this product?
Speak to a regulatory counsel about your specific HSN, IS, and supplier situation.
Speak to an Expert
Frequently asked
Does HSN 3920 91 90 require BIS certification?
No. No BIS Quality Control Order covers poly (vinyl butyral) plastic film, foil, or strip under this tariff line. Import is governed by the Central Pollution Control Board EPR registration regime under the Plastic Waste Management (Amendment) Rules, 2022, with MoEFCC prohibition rules and CBIC chemical-qualifier declarations applying as concurrent requirements.
Are the IUPAC name and CAS number declarations mandatory for every bill of entry under Chapter 39?
Yes. For all bills of entry under Chapter 39 filed on or after 01-10-2023, declaration of the IUPAC name and CAS number of constituent chemicals is mandatory per CBIC Circular 15/2023-Cus dated 07-06-2023 and Circular 18/2023-Cus dated 30-06-2023, in the format set out in Annex-1 to those circulars.
Does the single-use plastic prohibition under Rule 4(2) apply to poly (vinyl butyral) film imported under this HSN?
The prohibition applies to specified items listed in Rule 4(2) with effect from 01-07-2022; if the imported film is destined for use in a prohibited category, the import itself is barred. Rule 4(3) provides that the prohibition does not apply to commodities made of compostable plastic, and compliance with G.S.R. 807(E) dated 30-10-2023 amendments must also be confirmed.
Last verified against gazette notifications: 2026-05-16. Source: CPCB / MEFCC / DGFT / CBIC / Indian Customs CUSDATA.
Related