100% Polyester or Cotton Blend? The lab report will tell the truth.

Last month, one of our clients—a reputable garment importer from Mumbai faced a costly detention at JNPT. The supplier’s invoice declared “100% Cotton Woven Fabric,” the HSN code matched, and the duty calculation looked clean. But when Customs drew samples for testing, the lab report came back: 65% Polyester, 35% Cotton. The result? A misdeclaration penalty, re-assessment of duty, and a three-week delay that cost them their retail deadline.

This wasn’t a one-off case. In my three decades of handling textile clearances across Chennai, Nhava Sheva, Tuticorin, and Mundra, I’ve seen this scenario repeat itself more times than I can count. Sometimes it’s deliberate fraud by suppliers. Often, it’s sheer negligence an exporter who doesn’t verify their own product composition before shipping. Either way, the Indian importer bears the brunt.

If you’re importing textiles, fabrics, yarns, or ready-made garments into India, you need to understand two critical compliance areas that Customs is watching closely: Azo dyes testing and composition verification. Get either of these wrong, and you’re looking at penalties, shipment seizures, and damaged business relationships.

Why Customs Tests Textile Imports

India has strict regulations governing textile imports, particularly concerning hazardous chemicals and accurate product classification. When you file a Bill of Entry for fabric or garments, Customs has the authority—and increasingly, the inclination to draw samples and send them to government-approved laboratories for testing.

They’re checking two main things:

1. Presence of Banned Azo Dyes
Certain Azo dyes break down into carcinogenic amines that pose serious health risks. The Bureau of Indian Standards (BIS) and the Directorate General of Foreign Trade (DGFT) have banned the use of specific Azo dyes in textiles. If your imported fabric tests positive for these banned substances, the consignment can be rejected, destroyed, or re-exported at your expense.

2. Actual Fiber Composition
Is your “100% Polyester” actually polyester? Or is it a poly-cotton blend? Is that “Pure Silk” real silk or a synthetic substitute? Composition affects classification, which affects duty rates, GST applicability, and sometimes even import licensing requirements under the Foreign Trade Policy.

We handle polyester fabrics and yarns regularly. Customs draws samples to test for hazardous Azo dyes and to verify composition. If your supplier invoices “Cotton” but the lab finds “Polyester,” you face misdeclaration fines, duty differential recovery, and a black mark on your Importer Exporter Code (IEC). Always get a test report from the supplier matching Indian standards before shipment.

The Real Problem: Supplier Negligence and Intentional Misrepresentation

Here’s what I’ve learned from handling thousands of textile consignments: most composition mismatches aren’t malicious—they’re sloppy.

Many overseas suppliers, especially from China, Bangladesh, and Vietnam, don’t bother verifying their own product specs. They produce a poly-cotton blend but invoice it as “100% Cotton” because that’s what the buyer asked for months ago during the initial enquiry. They assume nobody will check.

Some do it deliberately to help importers save duty. Cotton fabrics might attract a different duty rate than polyester blends. A supplier might knowingly misdeclare to make the shipment “cheaper” on paper. But Indian Customs isn’t blind—they know the tricks, and their testing protocols are getting stricter every year.

Then there’s the Azo dye issue. Many suppliers use cheaper dyes without understanding—or caring—that those dyes are banned in India. They assume it’s the importer’s problem. And technically, it becomes exactly that once the goods land in India.

Common Mistakes Importers Make

Over the years, I’ve seen the same mistakes repeated by even experienced importers:

Trusting Supplier Invoices Blindly
Your supplier sends you a proforma invoice declaring “100% Viscose Fabric.” You assume it’s accurate and file your Bill of Entry accordingly. Customs tests it, finds 40% polyester, and you’re stuck explaining why your documents don’t match the actual goods.

Not Asking for Pre-Shipment Test Reports
Many suppliers can provide test reports from accredited labs confirming fiber composition and Azo dye compliance—if you ask. Most importers don’t. They treat it as an unnecessary cost. But that Rs 5,000 test report could save you Rs 5 lakh in penalties and delays.

Using Generic HSN Codes
Textiles have highly specific HSN codes based on fiber type, weave, weight per square meter, and finish. Using a generic or approximate code because you’re unsure of the exact composition is asking for trouble. Customs will reclassify, and you’ll pay the difference plus interest.

Assuming Small Consignments Won’t Be Tested
I’ve seen Customs draw samples from a single roll shipment worth $500. There’s no “safe” size. Risk-based sampling is getting more sophisticated, not more lenient.

Ignoring Past Test Results
If you’ve imported the same product from the same supplier before, and Customs tested it then, those results are on record. If this time the composition is different, you better have a good explanation—or proof that you changed suppliers or product specs.

Risks and Consequences of Getting It Wrong

Let me be very direct about what happens when textile composition or Azo dye compliance goes wrong:

Immediate Detention and Sampling
Your consignment gets held. Samples go to the lab. You’re looking at a minimum 10-15 day delay, sometimes longer if the lab is backlogged or if re-testing is needed.

Misdeclaration Penalties
Under Section 114 of the Customs Act, misdeclaration can attract penalties equal to the duty sought to be evaded or the value of goods, whichever is higher. We’ve seen penalties ranging from Rs 50,000 to several lakhs depending on the consignment value and degree of misdeclaration.

Duty Differential and Interest
If reclassification results in higher duty, you pay the difference plus applicable interest from the date of import. This can add 15-20% to your landed cost.

Seizure and Confiscation
If banned Azo dyes are found, Customs can seize the goods. You might have the option to re-export, but that involves demurrage, container detention charges, shipping costs back, and total loss of the business opportunity.

IEC Suspension or Blacklisting
Repeated violations can lead to your IEC being suspended or your firm being placed on a watchlist. This affects future clearances—every shipment gets extra scrutiny, which means more delays and costs.

Loss of Customer Confidence
If you’re importing for a retail deadline or a specific order, delays mean cancelled contracts, penalty clauses, and damaged relationships. I’ve seen businesses lose major clients over a single detained shipment.

How PKM Handles Textile Clearances Professionally

At Premji Kanji Masani, we’ve been clearing textiles since 1963. We’ve seen regulatory regimes change, port infrastructure modernize, and compliance requirements tighten. Here’s how we protect our clients:

Pre-Shipment Document Verification
Before your goods even leave the supplier’s warehouse, we review all documentation. We flag any discrepancies between the proforma invoice, packing list, and product description. If something doesn’t add up, we insist on clarification or testing before shipment.

Supplier Test Report Validation
We advise clients to obtain fiber composition reports and Azo dye test certificates from accredited labs in the country of origin. We cross-check these against BIS standards and Indian customs requirements. If the supplier can’t provide them, we recommend independent third-party testing before dispatch.

Accurate HSN Classification
Our team includes classification experts who stay updated on the latest HSN updates, notifications, and Central Board of Indirect Taxes and Customs (CBIC) circulars. We ensure your Bill of Entry reflects the exact product composition, avoiding both underpayment and overpayment of duty.

Proactive Engagement with Customs
When we anticipate potential issues—say, a mixed-composition fabric that might be borderline—we engage with the Appraising Officer early. We provide supporting documentation, technical specifications, and supplier certifications upfront, reducing the likelihood of sampling or disputes.

Liaison During Detention
If a consignment is detained for testing, we manage the entire process: following up with the testing lab, coordinating with Customs, arranging for re-assessment if needed, and minimizing demurrage and storage charges while the issue is resolved.

Compliance Training for Clients
We don’t just clear shipments; we educate our clients. We brief importers on what documents to demand from suppliers, what red flags to watch for, and how to build a compliant import process from the start.

Actionable Tips for Textile Importers

If you’re importing textiles or garments into India, here’s what you need to do:

Demand Test Reports from Your Supplier
Make it a contract condition. Ask for a fiber composition analysis and an Azo dye test certificate from a recognized lab. Ensure the test follows ISO or equivalent standards acceptable in India. Don’t accept vague assurances.

Verify Composition Matches Invoice
If you ordered “100% Cotton,” the test report should confirm 100% cotton, not 95% or “cotton-rich blend.” Even small deviations can trigger reclassification.

Know Your Product Inside Out
Don’t just rely on the supplier’s description. Understand the weave type, GSM (grams per square meter), finish, and any treatments applied. This helps in accurate HSN coding and realistic expectations during clearance.

Work with a Customs Broker Who Understands Textiles
Textile clearances require specific knowledge of BIS standards, DGFT policies, and Customs testing protocols. A broker who mostly handles machinery or electronics might miss critical textile compliance nuances.

Budget for Contingencies
Factor in the possibility of testing delays and potential duty reclassification when calculating your landed costs and delivery timelines. Hope for smooth clearance, but plan for the alternative.

Maintain Consistency with Previous Imports
If you’ve successfully imported the same product before, keep those test results and Bills of Entry handy. Consistency across shipments makes Customs less likely to suspect misdeclaration.

Don’t Cut Corners on Documentation
A complete set of documents—commercial invoice, packing list, bill of lading, country of origin certificate, supplier’s test reports, and any applicable BIS or quality certifications—makes clearance smoother and faster.

Final Thoughts: Protect Your Business, Stay Compliant

The textile import business can be highly profitable, but it’s also heavily regulated for good reasons. Banned Azo dyes pose real health risks to Indian consumers. Misdeclaration undermines fair trade and revenue collection. Customs is right to enforce these standards—and they’re getting better at it every year.

As an importer, you control your supply chain. You choose your suppliers. You decide whether to demand test reports or skip them to save a few dollars. You set the compliance standards for your business.

In my 30+ years in this industry, I’ve seen too many good businesses get hurt by avoidable mistakes. A delayed shipment, a surprise penalty, a confiscated consignment—these aren’t just financial losses. They damage your reputation, strain customer relationships, and create operational chaos.

The solution is simple: verify before you ship, document everything, and work with professionals who understand the complexities of textile import compliance.

Need Guidance on Textile Import Compliance?

At Premji Kanji Masani Private Limited, we’ve been guiding importers through India’s evolving customs landscape since 1963. Our team has hands-on experience with textile clearances at all major Indian ports and ICDs, and we understand the technical nuances of Azo dye regulations and composition verification.

Whether you’re importing your first fabric consignment or you’re a seasoned garment importer looking to tighten your compliance processes, we’re here to help. Let’s ensure your next shipment clears smoothly, accurately, and without unpleasant surprises.