CIB&RC · Non-insecticidal use
Scheduled substances other than boric acid imported for industrial, laboratory or pharmaceutical purposes still require prior CIB&RC permission.
What is a non-boric acid import permit?
It is a CIB&RC import permit for any substance listed in the Schedule to the Insecticides Act, 1968 other than boric acid, where the material is being imported for a purpose that is not insecticidal. The route mirrors the boric acid pathway: the applicant must substantiate the industrial end use and justify the quantity.
Regulatory update · current as at September 2026
The non-insecticidal import permit regime changed in July 2026. Gazette notification G.S.R. 597(E) dated 8 July 2026 notified the Insecticides Third (Amendment) Rules, 2026, inserting a new Chapter III-A into the Insecticides Rules, 1971 titled “Manner of Import of an Insecticide for Non-Insecticidal Purpose”, together with a new clause in Rule 4. The Registration Committee accepted the terms and conditions at its 474th meeting on 30 July 2026, and DPPQ&S issued an implementing public notice on 6 August 2026. Applications are now made in Form IA with a fee of Rs. 5,000. Pages describing the older, discretionary process are out of date.
Which substances fall into this category
The Schedule to the Insecticides Act, 1968 lists a wide range of chemicals, several of which have substantial non-agricultural markets. Importers frequently discover the requirement only when a consignment is detained. Substances commonly imported for non-insecticidal purposes include preservatives, fumigants used in non-agricultural settings, laboratory reference standards, intermediates that appear on the Schedule in their own right, and actives destined for formulation into products regulated under other laws.
The controlling question is simple and worth applying before every new import: is this exact substance named in the Schedule? If it is, the end use does not exempt you.
How the non-boric acid route differs in practice
The statutory basis is identical, but the assessment tends to be more searching. Boric acid has well-recognised industrial applications, so a ceramics or glass end use is readily understood. For less common substances, the Secretariat has fewer reference points and will probe harder on:
- Whether the declared industrial application is technically plausible for that molecule
- Whether a non-scheduled alternative exists that would serve the same purpose
- Whether the applicant has the manufacturing infrastructure to consume the quantity
- Whether the material could be readily diverted to pest control channels
This means the technical write-up carries more weight. We normally prepare it with the client's process chemist rather than treating it as a documentation exercise.
Documents required
- Application in the prescribed form to the Secretary, CIB&RC
- Company constitution documents, GST and Importer Exporter Code
- Factory licence, pollution control consent and industrial registration as applicable
- Technical justification of the end use with process flow and reaction scheme
- Chemical specification, certificate of analysis and safety data sheet
- Quantity computation tied to installed capacity and production plan
- Notarised undertaking against diversion to insecticidal use
- Proforma invoice with manufacturer, shipper and country of origin
- Utilisation record against earlier permits, for repeat applications
Practical sequencing advice
| Step | Why it matters |
|---|---|
| Confirm Schedule status before contracting | Avoids committing to a supply agreement you cannot lawfully perform |
| Fix the manufacturer and shipper on paper first | The permit is source-specific; changing it later requires a separate amendment |
| Compute quantity from real consumption data | Inflated figures are the most common cause of queries and reductions |
| File well ahead of the shipping window | Permits are not granted retrospectively as a matter of routine |
| Track validity against your shipping schedule | An extension application filed before expiry is far simpler than a fresh permit |
How JDR supports these applications
We begin with a Schedule screening so you know your exposure before you commit commercially. Where a permit is required, we build the technical justification alongside your process team, compute a defensible quantity, file the application and carry it through query resolution. We also maintain permit calendars for clients importing on a continuing basis, so amendments and extensions are filed before they become urgent.
Form IA: what the application must contain
Chapter III-A prescribes Form IA, addressed to the Registration Committee. Unlike the previous practice, the content is now specified rather than left to the applicant's judgement. Form IA requires:
| Field | What is required |
|---|---|
| Applicant | Name and address of the applicant |
| Premises | Address where the imported insecticide will be stored or used |
| Substance | The insecticide and its minimum purity |
| Source | Source of import |
| End product | The product manufactured using the imported material |
| Capacity | Licensed and installed production capacity |
| Technical function | The function the insecticide performs in the manufacturing process, and the percentage required |
| Quantity | Proposed annual import quantity |
| Facility evidence | Valid industrial licence or other specified evidence of the manufacturing facility |
| Environmental | Pollution Control Board clearance or consent |
| Historical usage | Quantity imported and consumed in each of the previous three financial years, with the corresponding production of the final product |
| Affidavit | Self-certified affidavit supporting the quantity requested |
Two additional declarations, depending on destination
- Material for domestic consumption — a declaration certified by the jurisdictional Industrial Health and Safety Office confirming that the imported insecticide will be stored separately from other materials, to avoid poisoning.
- Material for export — details of the foreign buyer, and an advance licence where applicable.
The applicant must certify that the imported material is not intended for sale but for the applicant's own stated requirement. Incorrect information can result in cancellation of the import permit, with the applicant bearing the resulting losses and responsibility.
The 30% rule — the provision most applicants miss
This is the single most consequential change for importers scaling up. Where the quantity proposed for import exceeds the average consumption of the previous three years by more than 30%, the application must carry detailed justification from the Nodal Ministry, Department, or State Department of Industry for the additional quantity.
Obtaining that justification is a separate administrative exercise with its own lead time, and it is outside the Registration Committee's control. In practice this means a company planning a significant capacity expansion should start the Nodal Ministry justification before, not after, filing Form IA. Applicants who discover the requirement at the query stage routinely lose a full quarter.
Statutory timelines and permit validity
| Provision | Position under Chapter III-A |
|---|---|
| Application | Form IA to the Registration Committee |
| Fee | Rs. 5,000 |
| Disposal of a complete application | Preferably within 45 days, extendable by up to 15 further days |
| Processing target stated in the guidelines | Preferably 30 days, or 4–6 weeks subject to the Registration Committee meeting calendar, from receipt of a complete application through the online portal |
| Standard permit validity | One year |
| Validity where the applicant holds a registration certificate for the pesticide in which the imported material is used as raw material | Three years |
| Incomplete applications | May be rejected without prior notice |
The three-year validity is worth planning around. An importer who also holds a Section 9 registration for the downstream pesticide gets a permit lasting three times as long, which removes two renewal cycles of administrative risk. Where a registration is close to grant, it can be worth sequencing the permit application after it.
Filing route and the reference-material exemption
Applications are filed through the online portal. The CROP portal (Computerised Registration of Pesticides) is the Registration Committee's electronic filing system, and the August 2026 public notice confirms that applications already received through CROP are being scrutinised under the new guidelines — so a pending pre-amendment application is not simply void, but it will be assessed against the new requirements.
One useful exemption: an import permit is not required for unit packs containing 5 grams or less of Certified Reference Material or Reference Standards of insecticides or pesticides. Analytical laboratories importing reference standards in small quantities have often applied unnecessarily.
Frequently Asked Questions
How do I know whether my chemical is scheduled under the Insecticides Act?
Check the substance against the Schedule to the Act by chemical name and CAS number rather than by trade name. Trade names and technical grades vary; the Schedule listing is what governs. We run this screening as a first step for new imports.
Is the process different from a boric acid permit?
The statutory route is the same. In practice, assessment of less common substances is more searching, so the technical end-use justification needs to be stronger.
Can I import under a non-insecticidal permit and later sell for pest control?
No. Doing so is a contravention of the Insecticides Act, 1968. Insecticidal marketing requires registration under Section 9 and the applicable manufacturing or sale licences.
Does a non-insecticidal use permit exempt me from other Indian regulations?
No. It addresses only the Insecticides Act. Depending on the substance you may also need clearances under chemical, drug, cosmetic, environmental or DGFT rules.
Reviewed: 22 September 2026 · Reflects the Insecticides Act, 1968 and Insecticides Rules, 1971 as amended, including the Insecticides Third (Amendment) Rules, 2026 (G.S.R. 597(E) dated 8 July 2026). General guidance only — confirm current requirements before acting.
Not sure whether your chemical is scheduled?
Send us the chemical name and CAS number. We will confirm the Schedule position and the permit route before you commit to a purchase order.
Talk to Our Regulatory Team