Other

Plastic plates, sheets, film and foil of phenolic resins

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 94 90 (other plates, sheets, film, foil and strip of phenolic resins) 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) prohibits specified single-use plastic items under Rule 4(2) of the same Rules, and DGFT policy overlays apply including port restrictions for imports from Bangladesh under DGFT Notification 7/2025-26.

What this is

HSN code

3920 94 90

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 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 portal before filing the bill of entry. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates registration for all importers of plastic packaging products, plastic sheets, carry bags, or multi-layered packaging, and Rule 7.3 prescribes EPR obligations that attach at the time of import.
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
Declare the IUPAC name and CAS number of all constituent chemicals 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, per 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 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). If originating from Bangladesh, confirm whether the port-restriction conditions in DGFT Notification 7/2025-26 dated 17-05-2025 (Para 19 General Notes, Para 1) apply or whether the consignment qualifies under the Para 2 or Para 3 exemptions.
Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022 · 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 EPR registration but failing to declare the IUPAC name and CAS number of constituent chemicals in the bill of entry — an omission that triggers a deficiency notice and holds the consignment at port pending correction. Registration on the CPCB portal and the CBIC chemical-qualifier declaration are independent mandatory requirements; satisfying one does not discharge the other. Additionally, importers should verify compliance with the Second Amendment Rules (G.S.R. 807(E) dated 30-10-2023), which introduced further obligations after the primary 2022 registration requirement.

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Frequently asked

Does HSN 3920 94 90 require BIS certification?

No, no BIS Quality Control Order covers non-cellular, non-reinforced plastic plates and film of phenolic resins under this tariff line. Import is governed by the Central Pollution Control Board under the Plastic Waste Management (Amendment) Rules, 2022, with MoEFCC single-use plastic prohibitions and CBIC chemical-qualifier declaration requirements also applying.

Is CPCB EPR registration required even if the product is not packaging material?

Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates CPCB portal registration for importers of plastic sheets and plastic packaging products; the obligation attaches to the importer entity, not solely to end-use packaging. If the imported phenolic-resin sheet is used in industrial applications not constituting plastic packaging, the importer should assess applicability against the definitions in Schedule II of the Rules and the G.S.R. 133(E) notification.

Do the single-use plastic prohibitions under Rule 4(2) apply to phenolic-resin film under this HSN?

The Rule 4(2) prohibition applies to specified categories including wrapping or packing films, plates, trays, and similar items effective 01-07-2022; phenolic-resin film or sheet that falls within those descriptions is prohibited from import, manufacture, stocking and sale. Items made of compostable plastic are carved out under Rule 4(3), but standard phenolic-resin film does not qualify for that exemption.

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