Flexible, plain

Flexible plain phenolic resin film, foil and strip

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 94 20 (Flexible, plain phenolic resin sheet/film) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration and compliance obligations under 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 regime and CBIC mandatory chemical-qualifier declarations under Chapters 28, 29, 32, 38 and 39 apply as additional clearance requirements, alongside Directorate General of Foreign Trade (DGFT) import policy conditions.

What this is

HSN code

3920 94 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 certificate from CPCB
IUPAC name and CAS number declaration to CBIC
SUp prohibition compliance declaration to CBIC

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 on the CPCB centralised EPR portal as an importer of plastic packaging under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 before filing the bill of entry. Rule 7.3 of the same Rules prescribes ongoing EPR obligations; failure to hold a current registration renders the consignment liable to detention pending regularisation.
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-Cus dated 22-06-2022
2
Declare the IUPAC name and CAS number of each constituent chemical in the bill of entry as a mandatory qualifier for Chapter 39 imports. These fields are mandatory for all bills of entry filed on or after 01 October 2023 in terms of 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
Verify that the goods do not fall within the Single-Use Plastic prohibition categories under Rule 4(2) of the Plastic Waste Management Rules (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). If importing 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.
Rule 4(2), Plastic Waste Management Rules · 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 conflating physical EPR registration on the CPCB portal with substantive EPR target fulfilment — importers frequently obtain the registration but neglect the ongoing annual reporting and target obligations under Rule 7.3, which CPCB may treat as a continuing violation attracting separate enforcement action. Additionally, the mandatory IUPAC/CAS qualifier fields for Chapter 39 bills of entry are assessed at the time of filing, not retrospectively; a bill of entry submitted without these fields on or after 01 October 2023 is rejected at the gateway, triggering avoidable demurrage.

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Frequently asked

Does HSN 3920 94 20 require BIS certification?

No. No BIS Quality Control Order covers flexible plain phenolic resin film or strip. Import is governed by the Central Pollution Control Board under the Plastic Waste Management (Amendment) Rules, 2022, with CBIC chemical-qualifier declarations and the MoEFCC Single-Use Plastic prohibition regime as concurrent requirements.

Are the IUPAC name and CAS number declarations mandatory for all Chapter 39 importers from 01 October 2023?

Yes. Per CBIC Circular 15/2023-Cus dated 07-06-2023 and Circular 18/2023-Cus dated 30-06-2023, the IUPAC name and CAS number of constituent chemicals are mandatory additional qualifiers on all bills of entry filed on or after 01 October 2023 for imports under Chapters 28, 29, 32, 38 and 39.

Does the Single-Use Plastic prohibition under Rule 4(2) apply to flexible phenolic resin film?

The prohibition targets specific commodity categories listed in Rule 4(2) effective 01-07-2022; importers must assess whether their specific product falls within those categories, noting that Rule 4(3) carves out commodities made of compostable plastic, and the Second Amendment Rules (G.S.R. 807(E) dated 30-10-2023) introduced further amendments that must be confirmed against the consignment's specification.

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