A report published recently, highlighted a customs enforcement issue concerning imports of chemicals listed under the Schedule to the Insecticides Act, 1968. It reported that CBIC Instruction No. 18/2026-Customs, dated 1 October, directed customs officers to enforce the import-permit requirement for scheduled chemicals even when the declared use was unrelated to pest control. Acrylonitrile was specifically identified as one of the affected chemicals.

Acrylonitrile is an important industrial chemical used in the manufacture of several products, including acrylonitrile-butadiene rubber (NBR), acrylic fibres and ABS plastics. NBR is particularly important to non-tyre rubber manufacturers because of its resistance to oils, fuels and many industrial fluids. It is used in seals, O-rings, gaskets, hoses, diaphragms and other engineered rubber components.

The reported enforcement position could have implications for importers and manufacturers whose supply chains involve acrylonitrile or other chemicals covered by the relevant legislation. Permit requirements can affect import lead times, documentation, customs clearance and inventory planning, even when the final application is industrial.

Manufacturers dependent on imported NBR related inputs should also review supplier lead times and maintain appropriate safety stocks. The key lesson is that industrial end-use alone should not be assumed to exempt a scheduled chemical from import control requirements.