Flexible

Flexible polyurethane plates, sheets, film and strip

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3921 13 10 (Flexible polyurethane plastic sheet and film) 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) single-use plastic prohibition and thickness-floor rules apply concurrently, and importers must declare IUPAC names and CAS numbers of constituent chemicals as mandatory bill-of-entry qualifiers under CBIC Circular 15/2023-Cus.

What this is

HSN code

3921 13 10

Chapter

39 · Plastics and articles thereof

Primary regulator

CPCB · Plastic Waste Management (Amendment) Rules, 2022 — EPR registration regime

Customs documentation

EPR registration certificate from CPCB
IUPAC/CAS 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 EPR portal before filing any bill of entry for plastic packaging. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates registration of importers of plastic packaging products, sheets, carry bags, and multi-layered packaging, and Rule 7.3 sets out the associated EPR obligations.
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-Customs dated 22-06-2022
2
At bill-of-entry filing, declare the IUPAC name and CAS number of each constituent chemical in the mandatory additional-qualifier fields for Chapter 39 imports. These fields are mandatory for all bills of entry filed on or after 01-10-2023 and are in addition to standard tariff declarations.
CBIC Circular 15/2023-Cus dated 07-06-2023 · CBIC Circular 18/2023-Cus dated 30-06-2023
3
Verify that the flexible polyurethane film does not constitute a prohibited single-use plastic item under Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022, and that any carry-bag or sheet product meets the 75-micron minimum (from 30-09-2021) and 120-micron minimum (from 31-12-2022) thickness floors. Confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 notified vide G.S.R. 807(E) dated 30-10-2023.
Rules 4(1)(c) and 4(2), Plastic Waste Management (Amendment) Rules, 2022 · G.S.R. 571(E) dated 12-08-2021 · G.S.R. 807(E) dated 30-10-2023

A word of counsel

The most common error on this tariff line is completing CPCB EPR portal registration but failing to upload or declare it at the bill-of-entry stage, leaving the consignment liable to detention while the customs proper officer awaits documentary confirmation. Separately, importers sourcing from Bangladesh must check DGFT Notification 7/2025-26 dated 17-05-2025: Para 19 of the General Notes to ITC (HS) 2022 introduced port restrictions on certain goods of Bangladeshi origin, and consignments of plastic film that fall within its scope must arrive through the specified ports or risk re-export under the ITC (HS) Restricted-import enforcement mechanism.

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Frequently asked

Does HSN 3921 13 10 require BIS certification?

No, flexible polyurethane plastic sheets and film are not within the BIS Quality Control Order regime. Import is governed by CPCB EPR registration obligations under the Plastic Waste Management (Amendment) Rules, 2022, with MoEFCC single-use plastic prohibitions and CBIC chemical-qualifier requirements applying as concurrent overlays.

Is CPCB EPR registration a one-time requirement or does it need to be renewed for each shipment?

Registration on the CPCB centralised portal is an entity-level obligation under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 — obtained once per importer — but EPR targets and annual reporting obligations under Rule 7.3 are continuous and must be fulfilled for each compliance year.

Does the single-use plastic prohibition under Rule 4(2) apply to flexible polyurethane film under this HSN?

The prohibition targets specifically listed commodities, including wrapping or packing films around sweet boxes, invitation cards, and cigarette packets; flexible polyurethane sheet used for industrial or packaging purposes outside those listed categories is not automatically prohibited, but importers must confirm the end-use description against Rule 4(2) before consignment departure, as a misdescribed end-use attracts seizure under the Plastic Waste Management Rules.

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