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Automotive air conditioning units for persons in vehicles

CPCB CLEARANCE · MEFCC CLEARANCE

HSN 8415 20 90 (Other automotive air conditioning units) is subject to Central Pollution Control Board (CPCB) Extended Producer Responsibility (EPR) authorisation under the E-Waste (Management) Rules, 2022 and to Ministry of Environment, Forest and Climate Change (MoEFCC) licensing controls under the Ozone Depleting Substances (ODS) Rules, 2000. Import of units containing ozone-depleting substances requires a licence from the Directorate General of Foreign Trade (DGFT) under General Note 8(a) of the ITC (HS) import policy; units free of ODS must carry a label confirming that status before import.

What this is

HSN code

8415 20 90

Chapter

84 · Nuclear reactors, boilers, machinery and mechanical appliances; parts thereof

Primary regulator

CPCB · E-Waste (Management) Rules, 2022 · ODS Rules, 2000

Customs documentation

EPR authorisation from CPCB
Import licence from DGFT
ODS-free label from importer

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.

Compliance steps

1
Obtain Extended Producer Responsibility authorisation from the Central Pollution Control Board before the bill of entry, unless the importing entity qualifies as a micro enterprise under the MSME Development Act, 2006. Air conditioners (excluding centralised air conditioning plants) fall under Schedule I of the E-Waste (Management) Rules, 2022, and import without a current EPR authorisation attracts detention and penalty.
Schedule I of the E-Waste (Management) Rules, 2022 · G.S.R. 801(E) dated 02-11-2022
2
If the unit contains any ozone-depleting substance listed in Schedule VII of the ODS Rules, 2000, secure an import licence from DGFT before shipment. Units that are ODS-free must carry a label stating that fact on the product before import, as required under Rule 10 of the ODS Rules, 2000 read with General Note 8(a) of the ITC (HS) Import Policy.
Rule 10 of the Ozone Depleting Substances (ODS) Rules, 2000 · General Note 8(a) of the ITC (HS) Import Policy

A word of counsel

The most common error on this tariff line is treating the ODS licence requirement and the EPR authorisation as alternatives rather than independent, concurrent obligations. An importer who secures the DGFT ODS licence for refrigerant-containing units but neglects CPCB EPR registration faces separate enforcement under the E-Waste (Management) Rules, 2022 — including seizure of the consignment — regardless of ODS compliance. The micro-enterprise exemption from EPR is narrow and requires affirmative Udyam registration; absent that credential, EPR authorisation is mandatory before out-of-charge.

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Frequently asked

Does HSN 8415 20 90 require BIS certification?

No, no BIS Quality Control Order covers this residual category of automotive air conditioning units. Import is governed by the Central Pollution Control Board under the E-Waste (Management) Rules, 2022 and by the Ozone Depleting Substances Rules, 2000 administered through the Ministry of Environment, Forest and Climate Change, with DGFT policy controls applying to ODS-containing units.

Does the EPR authorisation requirement apply to all importers of automotive air conditioners?

EPR authorisation under Schedule I of the E-Waste (Management) Rules, 2022 is mandatory for all importers except micro enterprises as defined in the MSME Development Act, 2006; centralised air conditioning plants are excluded from the EPR obligation under G.S.R. 801(E) dated 02-11-2022.

What labelling is required if the imported unit does not contain any ozone-depleting substance?

Per Rule 10 of the ODS Rules, 2000, ODS-free automotive air conditioning units must carry a label stating that the product does not contain ozone-depleting substances, and that label must be affixed before the consignment is imported into India.

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