Flexible, laminated

Flexible laminated plastic sheets, film and foil

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 3921 90 36 (Flexible, laminated plastic plates/sheets/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 (MoEF&CC) notifications G.S.R. 571(E) and G.S.R. 807(E) impose thickness and single-use-plastic prohibitions that apply at import, and CBIC chemical-qualifier declarations under Chapters 39 are mandatory at bill-of-entry stage.

What this is

HSN code

3921 90 36

Chapter

39 · Plastics and articles thereof

Primary regulator

CPCB · Plastic Waste Management (Amendment) Rules, 2022 — EPR registration and importer obligations

Customs documentation

EPR registration from CPCB
IUPAC/CAS qualifier declaration to CBIC
Single-use plastic compliance from MoEF&CC

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 portal before filing any bill of entry for plastic packaging or multi-layered plastic products. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 makes this registration mandatory for importers of plastic packaging products, carry bags, multi-layered packaging and plastic sheets; Rule 7.3 separately prescribes the EPR obligations the registered importer must discharge.
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 for all bills of entry filed under Chapter 39 on or after 01-10-2023. These additional qualifiers are mandatory in the electronic import declaration and must be submitted at the time of filing, not as a post-facto amendment.
CBIC Circular 15/2023-CUS dated 07-06-2023 · CBIC Circular 18/2023-CUS dated 30-06-2023 · Bill of Entry (Electronic Integrated Declaration and Paperless Processing) Regulations, 2018
3
Verify that the flexible laminated film or sheet does not constitute a prohibited single-use plastic item under Rule 4(2) of the Plastic Waste Management Rules (as amended by G.S.R. 571(E) dated 12-08-2021, effective 01-07-2022). 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-restriction applicability under Para 19 of the General Notes 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 common error on this tariff line is completing the CPCB EPR portal registration only once and treating it as a perpetual clearance, while missing the annual EPR target obligations under Rule 7.3 that accumulate with each import. A lapse in EPR target fulfilment is treated as a continuing violation under the Plastic Waste Management Rules, exposing the importer to Environment (Protection) Act, 1986 enforcement — prosecution, penalty and detention of subsequent consignments — independently of whether the original registration remains active on the portal.

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Frequently asked

Does HSN 3921 90 36 require BIS certification?

No, flexible laminated plastic sheets and film are not covered by any BIS Quality Control Order. Import is governed by the Central Pollution Control Board EPR registration regime under the Plastic Waste Management (Amendment) Rules, 2022, with MoEF&CC prohibitions on single-use plastic items applying at the point of import.

Are the IUPAC name and CAS number declarations mandatory for all bills of entry under this HSN, and from what date?

Yes. Per CBIC Circulars 15/2023-CUS and 18/2023-CUS, IUPAC and CAS number declarations are mandatory for all Chapter 39 import declarations filed on or after 01-10-2023, and must be entered at the time of filing, not as a subsequent amendment.

Do the single-use plastic prohibitions under Rule 4(2) apply to flexible laminated film imported under this HSN?

They apply where the laminated film or sheet falls within the enumerated prohibited categories — wrapping or packing films around sweet boxes, invitation cards or cigarette packets, and items under Rule 4(2)(b) listed in G.S.R. 571(E). Items made of compostable plastic are exempt under Rule 4(3), provided the compostability specification is substantiated at the bill of entry.

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