India Requires Import/Export Declarations for Some Products

By Thuy Dang, senior regulatory specialist, Supply Chain team, UL Solutions

The Indian Central Board of Indirect Taxes and Customs (CBIC) recently issued Circular No. 15/2023-Customs to mandate some submission of selected information for several chemical-related products, which previously have been declared voluntarily by importers. The mandatory declaration, previously set to be effective on Jul. 1, 2023, was extended to Oct. 1, 2023, per the requests of several trade associations’ representatives and the Department of Chemicals and Petrochemicals.

Circular 15 requires additional qualifiers to both import and export declaration, as follows:

• For imports: Declaration of IUPAC name and CAS number of constituent chemicals when importing products of the chemical or allied industries specified in the Customs Tariff Act, 1975, including:
  • Chapter 28: Inorganic chemicals, organic or inorganic compounds of precious metals, of rare-earth metals, of radioactive elements or of isotopes
  • Chapter 29: Organic chemicals
  • Chapter 32: Tanning or dyeing extracts; tannins and their derivatives; dyes, pigments and other colouring matter; paints and varnishes; putty and other mastics; inks
  • Chapter 38: Miscellaneous chemical products
  • Chapter 39: Plastics and articles thereof
• For exports: Declaration of various information includes:
  • Medicinal plants under Chapter 12 - Oil seeds and oleaginous fruits, miscellaneous grains, seeds and fruit; industrial or medicinal plants; straw and fodder
  • Formulation names of different streams of medicine under Chapter 30 - Pharmaceutical products
  • Surface material that comes into contact with the chemical for exports of various products under Chapter 84 - Nuclear reactors, boilers, machinery and mechanical appliances; parts thereof

The mandatory declaration resulted from the consultations with various ministries such as the Department of Chemicals and Petrochemicals, Ministry of AYUSH (Ayurveda, Yoga, and Naturopathy, Unani, Siddha and Homoeopathy) and the Directorate General of Foreign Trade (DGFT). The additional requirement aims to reduce queries and improve the assessment efficiency as chemical products can be associated with many common names or brand names, creating confusion for custom officers and delays in clearance. Using IUPAC name and CAS number, a unique identification to each chemical substance, gradually aligns to other global majority requirements.

Recommended actions

• Review the related circulars and regulations for more content of interest.
• Prepare the required information if your company plans to import or export to India starting from Oct. 1, 2023. 

References

• Circular No. 15/2023-Customs - Mandatory additional qualifiers in import/export declarations in respect of certain products wef 1.7.2023  
• Circular No. 18/2023-Customs - Mandatory additional qualifiers in import/export declarations in respect of certain products wef 1.7.2023 – Extension
• The Customs Tariff Act, 1975