Flexible, metallised

Flexible metallised plastic sheets, film, foil and strip

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3921 90 34 (Flexible, metallised plastic film/foil) 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) prohibitions on single-use plastics and thickness minima for carry bags apply at import, with Directorate General of Foreign Trade (DGFT) ITC (HS) policy overlays and IUPAC/CAS mandatory qualifier requirements under CBIC Circular 15/2023-Cus.

What this is

HSN code

3921 90 34

Chapter

39 · Plastics and articles thereof

Primary regulator

CPCB · Plastic Waste Management (Amendment) Rules, 2022 (EPR registration, Rule 6 and Rule 9(1) of Schedule II)

Customs documentation

EPR registration certificate from CPCB
IUPAC and CAS qualifier 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
Register as an importer on the CPCB centralised EPR portal under Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 before filing the bill of entry. Rule 7.3 prescribes extended producer responsibility obligations of importers, including targets for plastic-waste recovery; ensure the registration is current and valid at the time of import.
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 as mandatory additional qualifiers for imports under Chapter 39, for all bills of entry filed on or after 01-10-2023. These declarations are in addition to existing import declarations and failure to include them causes the bill of entry to be treated as incomplete.
CBIC Circular 15/2023-Cus dated 07-06-2023 · CBIC Circular 18/2023-Cus dated 30-06-2023
3
Verify the consignment does not consist of prohibited single-use plastic commodities under Rule 4(2) of the Plastic Waste Management Rules (effective 01-07-2022) and that any carry bags meet the 120-micron thickness minimum effective from 31-12-2022. Also check applicability of DGFT Notification 7/2025-26 dated 17-05-2025 regarding port restrictions on imports from Bangladesh under Para 19 of the General Notes to ITC (HS) 2022.
Rule 4(1)(c) and Rule 4(2) of the Plastic Waste Management (Amendment) Rules, 2022 · 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 at the entity level but failing to fulfil the annual EPR target obligations under Rule 7.3 before filing subsequent bills of entry — customs systems do not independently verify target compliance, but a CPCB audit or show-cause notice can trigger retrospective enforcement and consignment detention. Note also that the single-use plastic prohibition under Rule 4(2) applies to specific product forms within this tariff line; importers sourcing metallised wrapping or packing film for sweet boxes, invitation cards, or cigarette packets must confirm those sub-categories were not prohibited with effect from 01-07-2022.

Need a regulatory steer on this product?

Speak to a regulatory counsel about your specific HSN, IS, and supplier situation.

Speak to an Expert

Frequently asked

Does HSN 3921 90 34 require BIS certification?

No, flexible metallised plastic film and foil fall outside the BIS Quality Control Order regime; no BIS QCO covers this product family. Import is governed by the Central Pollution Control Board EPR registration framework under the Plastic Waste Management (Amendment) Rules, 2022, with MoEFCC single-use plastic prohibitions and CBIC mandatory chemical-qualifier requirements applying concurrently.

Are IUPAC name and CAS number declarations required for every bill of entry under Chapter 39?

Yes, for all bills of entry filed on or after 01-10-2023, the IUPAC name and CAS number of constituent chemicals are mandatory additional qualifiers for imports under Chapter 39 per CBIC Circular 15/2023-Cus dated 07-06-2023 and Circular 18/2023-Cus dated 30-06-2023.

Do the single-use plastic prohibitions under Rule 4(2) affect imports of metallised film used in packaging?

Yes, where the metallised film constitutes wrapping or packing film around sweet boxes, invitation cards, or cigarette packets, import of such forms is prohibited with effect from 01-07-2022 under Rule 4(2)(b) of the Plastic Waste Management (Amendment) Rules, 2022; the compostable-plastic carve-out under Rule 4(3) is the only exemption.

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