Rigid, plain

Rigid plain plastic plates, sheets, film and foil

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 99 11 (Rigid, plain plastic plates, sheets, film and foil of other plastics) 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 the manufacture and import of specified single-use plastic commodities with effect from 01-07-2022, and CBIC chemical-qualifier declarations under Chapters 28, 29, 32, 38 and 39 apply as a mandatory customs overlay.

What this is

HSN code

3920 99 11

Chapter

39 · Plastics and articles thereof

Primary regulator

CPCB · Plastic Waste Management (Amendment) Rules, 2022 (G.S.R. 133(E))

Customs documentation

EPR registration from CPCB
IUPAC/CAS qualifier declaration to 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 EPR 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 the EPR obligations that attach from the date of registration.
Rule 6 and Rule 7.3 of the Plastic Waste Management (Amendment) Rules, 2022 (G.S.R. 133(E) dated 16-02-2022); MoEFCC Letter F.No.B-17011/7/UPC-II-PWM(MLP)/2021/12900 dated 01-02-2022; CBIC Instruction 09/2022-Customs dated 22-06-2022
2
Verify the consignment is not a prohibited single-use plastic commodity under Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022, which prohibits import of specified items including wrapping or packing films around sweet boxes and invitation cards, trays, and PVC banners below 100 microns, with effect from 01-07-2022. Confirm carry bags are at or above 120 microns thickness per Rule 4(1)(c) (effective 31-12-2022). Ensure compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023).
Rule 4(1)(c) and Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022 (G.S.R. 571(E) dated 12-08-2021 and G.S.R. 133(E) dated 16-02-2022); G.S.R. 807(E) dated 30-10-2023
3
Declare the IUPAC name and CAS number of each constituent chemical at the time of filing the import declaration in e-Sanchit; these qualifiers are mandatory for all bills of entry under Chapter 39 filed on or after 01-10-2023. If the consignment originates from Bangladesh, assess applicability of the port restrictions and exemptions introduced under Para 19 of the General Notes to the ITC (HS) 2022 by DGFT Notification 7/2025-26 dated 17-05-2025.
CBIC Circular 15/2023-Cus dated 07-06-2023; CBIC Circular 18/2023-Cus dated 30-06-2023; DGFT Notification 7/2025-26 dated 17-05-2025

A word of counsel

The most common error on this tariff line is completing CPCB EPR registration and assuming compliance is achieved, while overlooking that the single-use plastic prohibition under Rule 4(2) is an absolute import ban — not a licensing threshold — for the enumerated commodity sub-types. An importer holding a current EPR registration who imports a prohibited single-use plastic form (for example, wrapping films around invitation cards or PVC banners below 100 microns) faces confiscation and prosecution under the Environment (Protection) Act, 1986 regardless of EPR status. The compostable-plastic carve-out under Rule 4(3) applies only to the commodities listed in Rule 4(2)(b) and requires documentary substantiation at port.

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Frequently asked

Does HSN 3920 99 11 require BIS certification?

No. No BIS Quality Control Order covers rigid plain plastic plates, sheets, film or foil under this tariff line. Import is governed by the Central Pollution Control Board under the Plastic Waste Management (Amendment) Rules, 2022, with a single-use plastic prohibition enforced by MoEFCC and mandatory CBIC chemical-qualifier declarations at the bill-of-entry stage.

Are the IUPAC name and CAS number declarations mandatory at filing, or can they be submitted post-clearance?

They are mandatory at the time of filing the import declaration itself — not post-clearance. Per CBIC Circulars 15/2023-Cus and 18/2023-Cus, these qualifiers must be declared for all Chapter 39 bills of entry filed on or after 01-10-2023, and non-declaration can result in the bill of entry being held pending correction.

Does the EPR registration exemption apply to compostable plastics?

Rule 4(3) of the Plastic Waste Management (Amendment) Rules, 2022 exempts commodities made of compostable plastic from the sub-rule 4(2)(b) single-use plastic prohibition, but EPR registration under Rule 6 and the producer responsibility obligations under Rule 7.3 remain applicable to compostable plastic packaging importers.

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