Rigid, lacquered

Rigid lacquered plastic plates, sheets, film and strip

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3921 90 31 (Rigid, lacquered plastic sheets and strip) 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 prohibitions under Rule 4(2) of those Rules and CBIC chemical-qualifier mandates under CBIC Circular 15/2023-CUS apply as additional clearance requirements.

What this is

HSN code

3921 90 31

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
SUP prohibition compliance declaration to 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
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 makes this registration mandatory for importers of plastic packaging products, plastic sheets, and multi-layered packaging; Rule 7.3 prescribes the EPR obligations that follow registration.
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 all constituent chemicals in the bill of entry as mandatory qualifiers for Chapter 39 imports. These fields are required for all bills of entry filed on or after 01-10-2023 in the format prescribed in Annex-1 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 consignment does not constitute a prohibited single-use plastic item under Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022, and confirm compliance with the Plastic Waste Management (Second Amendment) Rules, 2023. If importing from Bangladesh, assess applicability of DGFT Notification 7/2025-26 dated 17-05-2025 regarding port restrictions under Para 19 of the General Notes to ITC (HS) 2022.
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 common error on this tariff line is completing the CPCB portal registration and treating EPR compliance as concluded, while overlooking the IUPAC/CAS qualifier obligation at the bill-of-entry stage. Customs systems flag Chapter 39 bills filed without these chemical qualifiers as non-compliant regardless of CPCB registration status, and the consignment is held pending a revised declaration — accruing demurrage at the port of entry. The Rule 4(2) single-use plastic prohibition is a separate, goods-level bar: even a validly registered importer faces confiscation if the specific product falls within the prohibited commodity list.

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Frequently asked

Does HSN 3921 90 31 require BIS certification?

No, no BIS Quality Control Order covers rigid lacquered plastic plates and sheets. Import is governed by the Central Pollution Control Board's EPR registration regime under the Plastic Waste Management (Amendment) Rules, 2022, with additional MoEFCC single-use plastic prohibitions and CBIC chemical-qualifier requirements applying at the bill of entry.

Are the IUPAC name and CAS number declarations mandatory for all bills of entry under Chapter 39?

Yes. Per CBIC Circular 15/2023-CUS dated 07-06-2023, these qualifiers are mandatory for all Chapter 39 bills of entry filed on or after 01-10-2023 and must be declared in the format set out in Annex-1 to that circular.

Does the Rule 4(2) single-use plastic prohibition affect rigid lacquered sheets under this HSN?

It depends on end-use: wrapping or packing films, trays, and specific listed formats are prohibited from 01-07-2022 under Rule 4(2), but the prohibition does not apply to commodities made of compostable plastic per Rule 4(3). Importers should confirm the product specification against the prohibited-commodity list before shipment.

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