The Central Commission for Indirect Tariffs and Customs (CBIC) recently issued a new Customs Notice (Circular No. 15/2023-Customs), which obliges all imported chemicals to provide the IUPAC name and CAS number of 100% product components when declaring to the Customs. This new regulation encompasses organic chemicals, inorganic chemicals, precious metals, rare-earth metals, organic or inorganic compounds of radioactive elements or isotopes, uranium or coloring extracts, paints, paints, paintings, adhesives, ink, spice chemicals, plastics and other products.

The new regulation aims to optimize the declaration process for imported and exported chemicals, reduce queries and speed up customs time to improve the efficiency and benefits of imported and exported trade. However, as the information required by this mandatory regulation may involve business secrets, it has sparked strong controversy within the industry.

In response to industry concerns, CBIC issued Circular No. 18/2023-Customs on June 30, 2023, postponing the implementation date of this mandatory provision to October 1, 2023. In addition, the Customs mentioned in its latest notification that they could issue subsequent guidelines to guide to report information. These guidelines are expected to further clarify issues of business information protection and help better understand and comply with relevant regulations and safeguard their business secrets and intellectual property security.

In order to avoid delayed clearance, we remind relevant companies that trade with India to screen their export products in a timely manner to determine whether a component declaration is required.At the same time, companies should also closely follow the follow-up guidelines that CBIC may issue to ensure that their business secrets and intellectual property rights are protected while complying with the new regulations.