Chemicals

India is the sixth-largest producer of chemicals globally and the third-largest in Asia, with installed…

ISI MARK · 65 LINES · 45 STANDARDS

India is the sixth-largest producer of chemicals globally and the third-largest in Asia, with installed capacity exceeding 30 million tonnes across inorganic, organic, agrochemical, and petrochemical segments and a domestic market valued at approximately USD 220 billion. The Bureau of Indian Standards (BIS) has notified 17 eight-digit HSN codes drawn from three Customs Tariff chapters: Chapter 28 covering inorganic chemicals (phosphoric acid, hydrogen peroxide, sulphides, carbonates, peroxoborates), Chapter 29 covering organic intermediates (n-butyl acrylate, morpholine derivatives), and Chapter 39 covering food-contact and household plastic articles under HSN 3923 and HSN 3926. The controlled pool draws 18 Indian Standards, including IS 798 for phosphoric acid, IS 2080 for hydrogen peroxide, IS 12928 for n-butyl acrylate, IS 14625 for morpholine, and IS 17439 and IS 17483 for plastics in contact with food. All 17 HSN codes sit within the ISI Mark Scheme — no Compulsory Registration Scheme (CRS) overlap.

The dominant compliance instrument is the ISI Mark Scheme under Scheme-I of Schedule-II of the BIS Conformity Assessment Regulations, 2018, operationalised through product-specific Quality Control Orders issued by the Department for Promotion of Industry and Internal Trade (DPIIT) under Section 16 of the BIS Act, 2016: the Phosphoric Acid (Quality Control) Order against IS 798, the n-Butyl Acrylate (Quality Control) Order against IS 12928, the Morpholine (Quality Control) Order against IS 14625, and the Plastics (Quality Control) Order covering food-contact articles under HSN 3923 and HSN 3926 against IS 17439 and IS 17483. Layered above the BIS regime sit three parallel regulatory regimes that operate in concurrent jurisdiction, not in substitution: the Petroleum and Explosives Safety Organisation (PESO) under the Explosives Act, 1884 governs licensing of storage, transport, and import of hazardous chemicals; the Manufacture, Storage and Import of Hazardous Chemicals (MSIHC) Rules, 1989 under the Environment (Protection) Act, 1986, administered by the Central Pollution Control Board (CPCB) and state pollution boards, governs hazardous-chemical handling thresholds; and the Food Safety and Standards Authority of India (FSSAI) under the Food Safety and Standards (Packaging) Regulations, 2018 governs food-contact migration testing for the Chapter 39 cohort.

Five operational pain points recur in practice. First, dual-regulator overlap: a phosphoric acid consignment requires a valid FMCS licence under BIS for the producing plant, a PESO storage licence for the Indian importer's tank farm, and a CPCB hazardous-waste authorisation for site handling — clearance against one regulator does not cure non-compliance with the others. Second, hazardous-substance packaging: bulk drums and intermediate bulk containers (IBCs) carrying notified chemicals must bear UN-specification marks under the Recommendations on the Transport of Dangerous Goods, and a mismatch between the BIS-certified inner product and the UN-marked outer packaging triggers detention. Third, pharma-grade versus technical-grade scope under the same IS: IS 798 for phosphoric acid covers food and pharma grades within a single notification, and a CM/L licensed for technical grade cannot be supplied against pharmacopoeial-grade tenders. Fourth, residual-line misclassification on tariff residuary headings such as HSN 3923 90 90 and HSN 3926 90 99, where importers route notified food-contact plastic articles through residuary sub-headings to escape ISI scrutiny. Fifth, Authorised Indian Representative (AIR) liability exposure for foreign chemicals manufacturers — the AIR carries personal statutory liability under Rule 11 of the BIS Conformity Assessment Regulations, 2018 for the foreign plant's ongoing compliance.

At a glance

Tariff lines (8-digit HSN)

Indian Standards in industry

28 · 29 · 39

HSN chapters mapped

ISI

Primary mark scheme

Who it affects

Indian manufacturers

Indian manufacturers of phosphoric acid, hydrogen peroxide, n-butyl acrylate, morpholine, sulphides, carbonates, peroxoborates, and food-contact plastic articles within the 17 notified HSN codes must hold a CM/L licence under the ISI Mark Scheme against the applicable IS standard before any notified consignment is dispatched to the domestic market. Operating a phosphoric acid plant, peroxide unit, acrylate batch line, morpholine reactor, or food-contact plastic moulding facility without the applicable BIS certification exposes the unit to seizure of stock, retrospective penalty on past sales, and prosecution under Section 17 of the BIS Act, 2016, with monetary penalty up to INR 2 lakh under Sections 29 through 33 for a first offence and criminal liability including imprisonment up to two years for repeat offences. Chemical clusters around Dahej, Ankleshwar, Vapi, Vizag, and Cuddalore face concentrated enforcement risk because BIS surveillance officers coordinate cluster-level inspections with state pollution control board officers and PESO inspectors, with food-contact plastic units drawing additional FSSAI scrutiny under the Food Safety and Standards (Packaging) Regulations, 2018.

Foreign manufacturers

Foreign chemicals manufacturers — predominantly Chinese, Korean, Japanese, German, US, and Middle Eastern producers of phosphoric acid, hydrogen peroxide, n-butyl acrylate, morpholine, and notified inorganic intermediates, together with Southeast Asian and Chinese suppliers of food-contact plastic articles — must obtain a Foreign Manufacturers Certification Scheme (FMCS) licence under Scheme-I of the BIS Conformity Assessment Regulations, 2018 before any ISI-marked consignment clears Indian customs, with the typical application-to-grant timeline running 6 to 9 months. The pathway comprises application filing on manakonline.in, appointment of an Authorised Indian Representative (AIR), BIS officer travel to the producing plant for inspection of the reactor train, distillation column, packaging line, or moulding press, sample drawing for testing at a BIS-recognised Indian laboratory against the applicable IS specification, and grant of the product-and-facility-specific CM/L licence. The AIR named on the FMCS application carries personal statutory liability under Rule 11 of the BIS Conformity Assessment Regulations, 2018 for sample submission, surveillance-fee remittance, and the foreign plant's ongoing compliance, with chemicals AIRs additionally exposed to liability for hazardous-substance packaging integrity, UN-mark conformity, and PESO-CPCB coordination on the consignment paperwork.

Importers

Customs verification at Jawaharlal Nehru Port Trust (JNPT), Mundra, Kandla, Hazira, Vizag, and every container-handling Indian port is conducted in real time against the BIS portal (manakonline.in), overlaid with PESO import-clearance verification for hazardous chemicals and FSSAI cross-checks for food-contact plastic consignments. A lapsed, suspended, grade-mismatched, or sub-heading-mismatched FMCS licence on a phosphoric acid, hydrogen peroxide, n-butyl acrylate, morpholine, or food-contact plastic consignment results in immediate consignment detention at the wharf. Demurrage and ground rent on bulk-chemical cargoes — phosphoric acid in tank containers, hydrogen peroxide in IBCs, acrylate monomer in stabilised drums — accrue from day 1 of detention at rates that compound rapidly given the dangerous-goods storage surcharges levied by terminal operators. Importers should verify the supplier's CM/L number, the IS standard code, the certified grade (technical, food, or pharma), the producing plant address, and the UN-marked packaging specification on manakonline.in before placing each purchase order, because hazardous-chemical detentions resolve only through re-export, conditional release under bond, or confiscation under the Customs Act, 1962 read with Section 17 of the BIS Act, 2016.

Applicable Indian Standards

Tariff lines by chapter

Ch 28Inorganic chemicals; organic or inorganic compounds of precious metals334 lines Ch 29Organic chemicals1028 lines Ch 39Plastics and articles thereof430 lines

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Frequently asked

Does imported phosphoric acid need BIS?

Yes. Phosphoric acid within HSN 2809 20 10 and HSN 2809 20 20 falls under the Phosphoric Acid (Quality Control) Order issued by the Department for Promotion of Industry and Internal Trade (DPIIT) under Section 16 of the BIS Act, 2016, requiring BIS certification under the ISI Mark Scheme against IS 798. Foreign phosphoric acid plants exporting to India must hold a Foreign Manufacturers Certification Scheme (FMCS) licence in the producing plant's name with the typical timeline running 6 to 9 months, and the licence must distinguish technical grade from food and pharma grades because a single CM/L does not cover all three within IS 798.

How does the Plastics QCO interact with the FSSAI food-contact rules?

The Plastics (Quality Control) Order issued under Section 16 of the BIS Act, 2016 brings food-contact and household plastic articles within HSN 3923 and HSN 3926 cohorts under the ISI Mark Scheme against IS 17439 and IS 17483, while the Food Safety and Standards (Packaging) Regulations, 2018 administered by the Food Safety and Standards Authority of India (FSSAI) under the Food Safety and Standards Act, 2006 separately govern migration limits, overall migration into food simulants, and specific monomer residues for the same articles. The two regimes operate in concurrent jurisdiction, not in substitution: BIS certification does not exempt the importer or manufacturer from FSSAI compliance, and an FSSAI-cleared article without an ISI mark fails real-time customs verification on manakonline.in. Manufacturers and importers must hold both clearances before dispatch.

Are pharma intermediates under BIS QCO?

Selectively. Pharmaceutical intermediates fall under BIS Quality Control Orders only where the specific molecule has been notified through a product-specific QCO — currently active for phosphoric acid (IS 798, covers food and pharma grades), n-butyl acrylate (IS 12928), and morpholine (IS 14625, used in corrosion inhibition and as an intermediate in agrochemicals and rubber processing) under DPIIT-issued instruments. Pharma intermediates outside the notified perimeter remain governed by the Drugs and Cosmetics Act, 1940 and the Central Drugs Standard Control Organisation (CDSCO) under the Ministry of Health and Family Welfare, not by BIS. The CM/L grant letter under IS 798 distinguishes technical, food, and pharma grades, and a licence covering technical grade alone cannot be supplied against pharmacopoeial-grade contracts.

What is the PESO overlap on hazardous chemicals under BIS?

The Petroleum and Explosives Safety Organisation (PESO) under the Explosives Act, 1884 and the Static and Mobile Pressure Vessels (Unfired) Rules, 2016, together with the Manufacture, Storage and Import of Hazardous Chemicals (MSIHC) Rules, 1989 under the Environment (Protection) Act, 1986, govern licensing for storage, transport, and import of hazardous chemicals — including hydrogen peroxide, peroxoborates, and several Chapter 28 inorganic intermediates that also sit under BIS Quality Control Orders. The two regimes operate in concurrent jurisdiction: a valid PESO storage licence does not cure a missing BIS CM/L on the consignment, and a valid BIS FMCS does not cure absent PESO import clearance or CPCB hazardous-waste authorisation. Importers must hold all three clearances on file before the bill of entry filing, because customs cross-references each regulator's portal at the wharf.

Can a foreign chemicals manufacturer obtain FMCS?

Yes. A foreign manufacturer of phosphoric acid, hydrogen peroxide, n-butyl acrylate, morpholine, sulphides, carbonates, peroxoborates, or food-contact plastic articles within the 17 notified HSN codes files an FMCS application on the BIS portal (manakonline.in) under Scheme-I of Schedule-II of the BIS Conformity Assessment Regulations, 2018, appoints an Authorised Indian Representative (AIR) who carries personal statutory liability under Rule 11 of the same Regulations, hosts a BIS officer inspection at the producing plant, submits samples to a BIS-recognised Indian laboratory for testing against the applicable IS specification, and obtains a product-and-facility-specific CM/L licence carrying the manufacturer's CM/L number. The typical timeline runs 6 to 9 months from application filing to licence grant. The CM/L must name the producing plant address, not a trader, blender, or warehousing intermediary, and chemicals-sector AIRs should secure a written indemnity from the foreign principal before accepting appointment given the additional exposure on UN-mark conformity and PESO-CPCB coordination.

Last verified against gazette notifications: 2026-05-23. Source: BIS / DGFT / Indian Customs CUSDATA.