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Plastic film, foil and strip of other plastics

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 99 39 (plastic film, foil and strip of other plastics) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration under Rule 6 and Rule 9(1) 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 and thickness norms under the Plastic Waste Management Rules apply concurrently, with DGFT and CBIC policy overlays governing declaration requirements and import-policy conditions.

What this is
HSN code
3920 99 39
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
  • 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. 1
    Register as an importer on the CPCB centralised portal before the first bill of entry under the EPR framework. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates registration of importers of plastic packaging, carry bags, multi-layered packaging, and plastic sheets; Rule 7.3 prescribes EPR obligations that attach immediately upon 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. 2
    At the bill-of-entry stage, declare the IUPAC name and CAS number of each constituent chemical as mandatory additional qualifiers for Chapter 39 imports. These fields must be populated in the import declaration for all bills of entry filed on or after 01-10-2023 under 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. 3
    Verify that the goods do not constitute single-use plastic items prohibited under Rule 4(2) of the Plastic Waste Management Rules from 01-07-2022, and that any carry bag or wrapping film meets the applicable thickness norms (75 microns from 30-09-2021; 120 microns from 31-12-2022). Confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023) and, where goods originate from Bangladesh, verify applicability of DGFT Notification 7/2025-26 dated 17-05-2025 (Para 19 port restrictions).
    Rule 4(1)(c), Rule 4(2) and Rule 4(3) of the Plastic Waste Management Rules as amended · 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
A word of counsel

The most common error on this tariff line is completing CPCB EPR registration but failing to satisfy Rule 7.3 EPR obligations — specifically the annual targets for plastic waste collection and recycling — before filing repeat import declarations. Registration on the centralised portal is a threshold requirement; non-fulfilment of ongoing EPR targets after registration constitutes a separate and continuing violation under the Plastic Waste Management (Amendment) Rules, 2022, exposing the importer to MoEFCC enforcement independent of customs clearance. Confirm that the Second Amendment Rules, 2023 (G.S.R. 807(E)) have not altered the applicable category thresholds for the specific product sub-type being imported.

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Frequently asked
Does HSN 3920 99 39 require BIS certification?
No. No BIS Quality Control Order covers this residual plastic film and strip tariff line. Import is governed by the Central Pollution Control Board under the Plastic Waste Management (Amendment) Rules, 2022 (G.S.R. 133(E)), with MoEFCC prohibition and thickness-norm compliance as a concurrent requirement.
Are the IUPAC name and CAS number declarations at the bill of entry mandatory for this HSN?
Yes. For all bills of entry filed on or after 01-10-2023, importers must declare the IUPAC name and CAS number of constituent chemicals for Chapter 39 goods as mandatory additional qualifiers under CBIC Circulars 15/2023-Cus and 18/2023-Cus; failure to populate these fields will prevent out-of-charge.
Do the single-use plastic prohibitions under Rule 4(2) apply to all goods classified under this tariff line?
Only where the imported goods fall within the enumerated categories — including wrapping or packing films around sweet boxes, invitation cards, and cigarette packets — prohibited from 01-07-2022; items made of compostable plastic are exempt under Rule 4(3), and carry bags must meet the 120-micron thickness threshold from 31-12-2022.
Last verified against gazette notifications: 2026-05-16. Source: CPCB / MEFCC / DGFT / CBIC / Indian Customs CUSDATA.
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