Flexible, lacquered

Flexible lacquered plastic sheets, film, foil and strip

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3921 90 22 (Flexible, lacquered plastic film, foil and strip) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) registration under Rule 6 and Rule 9(1) of Schedule II of the Plastic Waste Management (Amendment) Rules, 2022. The Ministry of Environment, Forest and Climate Change (MoEFCC) prohibits import of specified single-use plastic commodities with effect from 01-07-2022, and mandatory IUPAC-name and CAS-number qualifiers apply under Directorate General of Foreign Trade (DGFT) and Central Board of Indirect Taxes and Customs (CBIC) overlay from 01-10-2023.

What this is

HSN code

3921 90 22

Chapter

39 · Plastics and articles thereof

Primary regulator

CPCB · Plastic Waste Management (Amendment) Rules, 2022 (EPR registration and SUP prohibition)

Customs documentation

EPR registration certificate from CPCB
Chapter 39 IUPAC and CAS qualifiers from CBIC
ITC (HS) policy declaration 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 this registration for importers of plastic packaging products, plastic sheets, or multi-layered packaging, and Rule 7.3 prescribes the consequent EPR obligations of importers.
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 each constituent chemical in the bill of entry at the time of filing. These qualifiers are mandatory for all bills of entry under Chapter 39 filed on or after 01-10-2023 and must be entered in the manner prescribed in the Annex to CBIC Circular 15/2023-Cus.
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 — in particular, wrapping or packing films around sweet boxes, invitation cards or cigarette packets, and PVC banners under 100 microns. Confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023) and, where the consignment originates from Bangladesh, check port restrictions under Para 19 of the General Notes introduced by DGFT Notification 7/2025-26 dated 17-05-2025.
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 frequent error on this tariff line is completing the CPCB EPR portal registration but failing to renew or update EPR targets annually — registration alone does not satisfy Rule 7.3 EPR obligations, which impose year-on-year recycling targets on importers of plastic packaging. A consignment cleared through customs with a lapsed or unfulfilled EPR target exposes the importer to MoEFCC enforcement independently of the customs clearance already obtained. Separately, importers sourcing from Bangladesh must verify port restrictions under DGFT Notification 7/2025-26 before vessel departure, as port non-compliance triggers detention regardless of EPR status.

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Frequently asked

Does HSN 3921 90 22 require BIS certification?

No. No BIS Quality Control Order covers flexible lacquered plastic film, foil or strip under this tariff line. Import is governed by the Central Pollution Control Board EPR registration regime under the Plastic Waste Management (Amendment) Rules, 2022, with single-use plastic prohibitions enforced by the Ministry of Environment, Forest and Climate Change.

Are the IUPAC name and CAS number declarations mandatory at the time of filing the bill of entry for Chapter 39 goods?

Yes. Per CBIC Circulars 15/2023-Cus dated 07-06-2023 and 18/2023-Cus dated 30-06-2023, IUPAC name and CAS number declarations are mandatory for all bills of entry under Chapter 39 filed on or after 01-10-2023; missing declarations result in the bill of entry being rejected at filing stage.

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

No. Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022 prohibits specific commodities — including wrapping films around sweet boxes, invitation cards and cigarette packets, and PVC banners under 100 microns — but the carve-out under Rule 4(3) exempts commodities made of compostable plastic from the sub-rule (2)(b) prohibition.

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