Flexible, plain
Flexible plain amino-resin plastic sheets, film, foil
HSN 3920 93 20 (Flexible, plain, of amino-resins) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration 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 prohibition under Rule 4(2) of those Rules and Directorate General of Foreign Trade (DGFT) ITC (HS) policy controls, including Chapter 39 IUPAC/CAS-number declaration requirements, apply as additional clearance obligations.
- EPR registration certificate from CPCB
- IUPAC and CAS declaration from CBIC
- Import 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 centralised CPCB portal under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022, and comply with EPR obligations prescribed under Rule 7.3. Registration must be current at the time of filing each bill of entry; import of plastic packaging without CPCB portal registration exposes the consignment to detention and penalty under the Environment (Protection) Act, 1986.Rule 6 and Rule 7.3, Plastic Waste Management (Amendment) Rules, 2022 · G.S.R. 133(E) dated 16-02-2022 · CBIC Instruction 09/2022-Customs dated 22-06-2022
- 2Declare the IUPAC name and CAS number of each constituent chemical in the bill of entry at the time of filing, as mandatory qualifiers for all imports under Chapter 39. This requirement applies to all bills of entry filed on or after 01-10-2023 and is in addition to existing import declarations.CBIC Circular 15/2023-CUS dated 07-06-2023 · CBIC Circular 18/2023-CUS dated 30-06-2023
- 3Verify that the flexible amino-resin plastic product does not fall within the single-use plastic prohibition categories under Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022 (effective 01-07-2022), and confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023). Additionally, check applicability of DGFT Notification 7/25-26 dated 17-05-2025 regarding para 19 port restrictions on imports from Bangladesh.Rule 4(2), Plastic Waste Management (Amendment) Rules, 2022 · G.S.R. 807(E) dated 30-10-2023 · DGFT Notification 7/25-26 dated 17-05-2025
The most common error on this tariff line is treating CPCB EPR registration as a one-time formality rather than a continuing compliance obligation: importers who register but fail to update their EPR targets or file annual returns on the CPCB portal remain non-compliant and face consignment-level detention on subsequent bills of entry. Separately, the single-use plastic prohibition under Rule 4(2) applies to specific product forms regardless of resin type — verify the end-use description of the flexible amino-resin sheet against the prohibited-category list before each shipment.