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HomeHSNChapter 39HSN 3920 99 60

Clicking boards for leather machinery

Clicking boards for leather cutting machinery

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3920 99 60 (Clicking boards for leather machinery) 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 (MoEF&CC) notified the Single Use Plastic prohibition regime via G.S.R. 571(E) dated 12-08-2021, and IUPAC name and CAS number declarations are mandatory at bill-of-entry filing under CBIC Circular 15/2023-Cus dated 07-06-2023.

What this is
HSN code
3920 99 60
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 and CAS declaration from CBIC
  • Chapter 39 qualifiers from 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. 1
    Register as an importer on the CPCB centralised EPR portal under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022, before the first bill of entry is filed. Rule 7.3 of the same Rules prescribes ongoing EPR obligations on importers of plastic packaging products, including reporting and fulfilment targets.
    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. 2
    Declare the IUPAC name and CAS number of all constituent chemicals at the time of filing the import declaration; these are mandatory Chapter 39 qualifiers for all bills of entry filed on or after 01-10-2023. Non-declaration results in the bill of entry being treated as deficient at the gate.
    CBIC Circular 15/2023-Cus dated 07-06-2023 · CBIC Circular 18/2023-Cus dated 30-06-2023
  3. 3
    Confirm that the consignment does not fall within the Single Use Plastic prohibition under Rule 4(2) of the Plastic Waste Management Rules as amended by G.S.R. 571(E) dated 12-08-2021 and further amended by G.S.R. 807(E) dated 30-10-2023. If importing via Bangladesh origin, verify applicability of port restrictions under Para 19 of the General Notes to ITC (HS) 2022 per DGFT Notification 7/2025-26 dated 17-05-2025.
    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 overlooked obligation on this tariff line is the distinction between the product-prohibition check and the EPR registration: clicking boards themselves are not Single Use Plastic items, but an importer who has not registered on the CPCB EPR portal is in breach of Rule 6 from the date of first import — regardless of the product's end use. Customs out-of-charge does not cure a missing EPR registration; CPCB enforcement actions, including monetary penalty under the Environment (Protection) Act, 1986, run independently of customs clearance.

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Frequently asked
Does HSN 3920 99 60 require BIS certification?
No, clicking boards for leather machinery are not covered by any BIS Quality Control Order. Import compliance is governed by the Central Pollution Control Board under the Plastic Waste Management (Amendment) Rules, 2022, with IUPAC and CAS number declaration requirements administered by CBIC.
Are the IUPAC name and CAS number declarations mandatory even for a specialised plastic article like a clicking board?
Yes. CBIC Circular 15/2023-Cus dated 07-06-2023 mandates these qualifiers for all imports under Chapter 39 for bills of entry filed on or after 01-10-2023, with no product-specific exemption for industrial plastic articles.
Does the Bangladesh port-restriction under DGFT Notification 7/2025-26 apply to clicking boards?
It applies where the goods originate from or are imported via Bangladesh and are not covered by the exemptions in Para 2 and Para 3 of Para 19 of the General Notes to ITC (HS) 2022; importers must verify origin and port eligibility before shipment.
Last verified against gazette notifications: 2026-05-16. Source: CPCB / MEFCC / DGFT / CBIC / Indian Customs CUSDATA.
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