Flexible, plain
Flexible plain polyamide film, sheet or foil
HSN 3920 92 92 (Flexible, plain polyamide film) is subject to Central Pollution Control Board (CPCB) registration and Extended Producer Responsibility (EPR) 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 prohibitions under Rule 4(2) of the same Rules and Directorate General of Foreign Trade (DGFT) ITC (HS) policy controls apply as additional clearance requirements. Importers must also declare IUPAC name and CAS number for Chapter 39 goods at the bill-of-entry stage under CBIC Circular 15/2023-Cus.
- EPR registration certificate from CPCB
- IUPAC and CAS declaration from CBIC
- ITC (HS) policy compliance from DGFT
Procedural directions for customs clearance are issued by: Directorate General of Foreign Trade, Central Board of Indirect Taxes and Customs.
- 1Register as an importer on the CPCB centralised EPR portal before the first consignment is filed. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates registration of importers of plastic packaging, sheets, or multi-layered packaging, and Rule 7.3 prescribes the EPR obligations that attach to that registration.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
- 2At the time of filing the bill of entry, declare the IUPAC name and CAS number of each constituent chemical of the polyamide film in the mandatory additional-qualifier fields in e-Sanchit. This obligation applies to all bills of entry for Chapter 39 goods 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
- 3Verify that the goods do not fall within the single-use plastic prohibitions under Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022 and confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023. If the consignment originates from Bangladesh, check applicability of port restrictions under Para 19 of the DGFT General Notes introduced by 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
The most common error on this tariff line is obtaining CPCB EPR registration after the first consignment is imported rather than before. EPR registration is a pre-import obligation under Rule 6; an importer who clears a consignment without a valid registration is not merely subject to a procedural cure — the import itself constitutes a violation of the Plastic Waste Management (Amendment) Rules, 2022, exposing the importer to detention of subsequent consignments and monetary penalty. The IUPAC and CAS qualifier fields are a separate, bill-of-entry-level obligation that customs officers verify independently of EPR status.