Rigid, lacquered
Rigid lacquered plastic plates, sheets, film, foil
HSN 3921 90 91 (Rigid, lacquered plastic sheets and foil) 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 under Rule 4(2) and the ITC (HS) policy administered by the Directorate General of Foreign Trade (DGFT) apply as additional clearance requirements. Importers must also declare IUPAC names and CAS numbers for Chapter 39 goods at bill-of-entry stage per CBIC Circular 15/2023-Cus.
- EPR registration certificate from CPCB
- IUPAC and CAS declaration from CBIC
- Single-use plastic compliance from MoEFCC
Procedural directions for customs clearance are issued by: Directorate General of Foreign Trade, Central Board of Indirect Taxes and Customs.
- 1Register as an importer on the CPCB centralised EPR portal before filing any bill of entry for plastic packaging or plastic sheet goods under this tariff line. Rule 6 of the Plastic Waste Management (Amendment) Rules, 2022 mandates registration, and Rule 7.3 prescribes the EPR obligations of importers, including targets for plastic waste collection and channelisation.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
- 2At the time of filing the bill of entry, declare the IUPAC name and CAS number of each constituent chemical in the Chapter 39 goods as a mandatory qualifier. These declarations are required for all bills of entry filed on or after 01-10-2023 and are in addition to existing import declarations.CBIC Circular 15/2023-Cus dated 07-06-2023 · CBIC Circular 18/2023-Cus dated 30-06-2023
- 3Verify that the goods do not fall within the single-use plastic categories prohibited under Rule 4(2) of the Plastic Waste Management Rules, 2021 (G.S.R. 571(E) dated 12-08-2021), including wrapping or packing films around certain goods and PVC banners below 100 microns. Also ensure compliance with the Plastic Waste Management (Second Amendment) Rules, 2023 (G.S.R. 807(E) dated 30-10-2023), and assess applicability of DGFT Notification 7/2025-26 dated 17-05-2025 regarding Bangladesh-origin import port restrictions under Para 19 of the General Notes of ITC (HS) 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
The most common error on this tariff line is treating CPCB registration as a post-importation administrative formality rather than a pre-filing prerequisite. Registration on the CPCB EPR portal must be active before the bill of entry is filed; consignments cleared without valid EPR registration expose the importer to seizure and monetary penalty under the Environment (Protection) Act, 1986 and retrospective CPCB enforcement. Importers should also separately audit whether any specific product variant within this 8-digit heading qualifies as a prohibited single-use plastic under Rule 4(2), since the prohibition on certain packing films and wrapping materials is product-specific and not self-evident from the tariff description alone.