India Makes Import Permits Mandatory for Acrylonitrile and Other Insecticide-Listed Chemicals, Even for Non-Pesticide Use
07 October 2026, New Delhi: India’s Central Board of Indirect Taxes and Customs (CBIC) has directed customs officers nationwide to enforce a long-disputed rule: any chemical listed in the Schedule to the Insecticides Act, 1968 now requires an import permit even when the importer plans to use it for something that has nothing to do with pest control. The directive, Instruction No. 18/2026-Customs, dated October 1, 2026, specifically names acrylonitrile, a chemical used widely to make acrylic fibers, ABS plastics and synthetic rubber, as a substance now squarely covered by the requirement.
The instruction closes a loophole that had let some importers skip the permit process. Several companies, including Apcotex Industries, had imported acrylonitrile without a permit after a Gujarat High Court ruling found that the Insecticides Act’s permit requirement should not apply when the chemical is imported for non-insecticidal industrial use. CBIC’s new instruction effectively supersedes that reasoning for customs purposes, stating that obtaining an import permit “is a statutory requirement” for all applicants bringing in Schedule-listed substances, regardless of end use, unless a specific exemption applies.
The legal basis traces back to a gazette notification of July 8, 2026, which introduced the Insecticides (Third Amendment) Rules, 2026. India’s Registration Committee, the technical body under the Central Insecticides Board that administers the Insecticides Act, discussed the amendment at its 474th meeting on July 30, 2026. CBIC’s October 1 instruction is the enforcement follow-through, telling customs field formations exactly how to apply the rule at the border.
Under the new process, companies seeking to import a Schedule-listed chemical for non-insecticidal use must file Form IA with the Registration Committee along with a fee of Rs 5,000. The rules set a target processing time of 45 days, extendable by up to 15 additional days in complex cases. Approved permits are valid for one year, except where the importer already holds a pesticide registration certificate covering that chemical as a raw material, in which case the permit runs for three years. Applicants must also submit supporting paperwork, including industrial licenses, pollution control board clearances, a three-year consumption history for the chemical, and a justification for the quantity requested. A narrow exemption applies to certified reference materials imported in unit packs of 5 grams or less, which do not need a permit.
For acrylonitrile specifically, the instruction removes the ambiguity that had let some importers argue they fell outside the Insecticides Act’s reach simply because their intended use was industrial rather than agricultural. Going forward, that argument will not hold at Indian ports: if a chemical appears on the Schedule, a permit is required no matter what the importer plans to do with it, unless the shipment qualifies for the reference-material exemption.
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