India Updates Azo Dye Requirements for Imported Apparel and Textile Products

SG 129/23

Import of textiles and textile articles to India is permitted subject to the condition that they shall not contain any hazardous dyes. The import consignments must be accompanied by a pre-shipment certificate (PSC) from a textile testing laboratory accredited to the National Accreditation Agency (NAA) of the country of origin.

Consumer products that contain the listed aromatic amines originating from restricted azo dyes are currently prohibited from being manufactured or sold in many countries including India. India has published legislation prohibiting the handling of a total of 112 azo- and benzidine-based dyes. In 1993, the Government of India prohibited the handling of 42 benzidine-based dyes. The Ministry of Environment and Forests further prohibited the handling of an additional 70 azo dyes in 1997. According to the Indian import policy, the import of textiles and textile articles is permitted subject to the condition that they do not contain any of the hazardous dyes (azo dyes) whose handling, production, carriage or use is prohibited in India under the provisions of the Environment  (Protection) Act, 1986. This amendment was made to the Indian legislation by the Notification No. 03 (RE-2001)/1997-2002 dated on 31 March 2001.

Under the Notification of Ministry of Commerce No. 19/2015-2020 dated 4.09.2015, the import consignments shall be accompanied by a pre-shipment certificate (PSC) from a textile testing laboratory accredited to the National Accreditation Agency (NAA) of the country of origin, certifying that the products do not contain any of the prohibited substances under azo dyes (Table 1). Testing must be done for every style and color to ensure compliance with the azo requirement.

In cases where such certificates are not available, the consignment will be cleared after getting the sample of the imported consignment tested and certified by any of the government approved laboratory in India for azo dyes and fiber composition. The sampling will be based on the following parameters:

1. At least 25% of the samples are drawn for testing instead of 100% for the presence of azo dyes (refer Table 1 the list of banned amines) and fiber composition. Exporters must reserve 25% of the samples for testing
2. When drawing samples, Customs will ensure the majority are drawn from the consignments originating from the countries where there is no legal prohibition on the use of harmful hazardous dyes
3. Test reports will be valid for the period of six months in cases where textile articles of the same specification or quality is imported, and the importer or supplier and the country of origin are the same
4. Consignment will be released after a pass result is obtained 
5. Exporter or Importer is liable for legal or economic consequences arising from non-compliance

A recent amendment, No: 14/2023 dated: 14 June 2023, clarifies that testing of textiles and textile articles for the presence of azo dyes will not be required for imports originating from the following countries:

1. European Union countries
2. Serbia
3. Poland
4. Denmark
5. Australia
6. Canada
7. Japan
8. South Korea
9. United Kingdom

Textile products imported with pre-shipment certificate:

• A pre-shipment certificate ensures products meet mandatory safety, quality and security requirements as required by the India’s textile import regulations
• Imported textile consignments with a pre-shipment inspection certificate can expediate customs clearance
• Pre-shipment certification will reduce the risk of a consignment being rejected at destination and potential economic losses

The key elements in pre-shipment certification are:

1. Physical inspection of the consignment prior to shipment
2. Sampling, testing and analysis in accredited laboratories.
3. Pre-shipment certification (PSC)

Table 1 Prohibited Substances under Azo Dyes

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