Subheading 2904 20 of the Combined Nomenclature covers derivatives of hydrocarbons containing only nitro or nitroso groups as functional substituents. This includes compounds such as nitromethane (CH3NO2), nitroethane, 1-nitropropane, 2-nitropropane, nitroglycerine (glycerol trinitrate, used in medicine and industry), nitrobenzene, nitrotoluene, dinitrotoluene (DNT) and trinitrotoluene (TNT). The scope of the subheading is defined by Note 1 to Chapter 29 of the CN: only separately chemically defined organic compounds fall within this chapter, meaning that mixtures of several compounds are classified elsewhere. Compounds possessing nitro or nitroso groups in combination with other functional groups (sulphonic, amino, hydroxyl) are classified in other subheadings corresponding to their specific functional group combination. Classification is carried out according to the General Rules for the Interpretation (GRI) of the CN, in particular Rule 1 and Rule 6 for subheadings. The Explanatory Notes to the HS and CN are key interpretative references. In case of doubt, a Binding Tariff Information (BTI) ruling is strongly recommended.

Importing nitro and nitroso derivatives of hydrocarbons into the European Union is subject to strict chemical regulations. REACH Regulation (EC) No 1907/2006 requires importers to register substances placed on the EU market at 1 tonne or more per year with the European Chemicals Agency (ECHA). Nitrobenzene, dinitrotoluene and nitroglycerine are listed as Substances of Very High Concern (SVHC) or are subject to restrictions under Annex XVII of REACH. CLP Regulation (EC) No 1272/2008 requires correct classification, labelling and packaging of substances before placing on the EU market — nitro compounds are typically classified as explosive (Expl. hazard class), flammable or toxic. A Safety Data Sheet (SDS) compliant with Regulation (EU) 2020/878 (16-section ECHA format) is a mandatory document when importing and supplying substances in the supply chain. Substances of Very High Concern may require REACH authorisation before use in the EU. Some nitro compounds (e.g. TNT) may be subject to dual-use export and import controls under Regulation (EU) No 2021/821. The importer must hold an EORI number, submit a customs declaration and fulfil all REACH and CLP obligations.

MFN (Most Favoured Nation) duty rates for goods under subheading 2904 20 must be verified in the European Commission's TARIC database, as they are subject to change following tariff reviews. Preferential duty rates may be available under Free Trade Agreements concluded by the EU, including CETA (Canada), the EU-Japan EPA, the EU-South Korea agreement and the EU-UK TCA, as well as under the Generalised Scheme of Preferences (GSP) for developing countries. Obtaining a preferential rate requires compliance with rules of origin and presentation of a valid proof of origin: EUR.1 certificate, invoice declaration or REX statement. The importer should verify in TARIC whether anti-dumping or countervailing measures apply to the specific product and country of origin. Imports from Russia and Belarus are subject to restrictions under EU sanction packages. The legal basis for import is the Union Customs Code (Regulation (EU) No 952/2013). Subheading 2904 20 falls within Section VI (Chemical industry products), Chapter 29 — organic chemicals. All duty rates and trade measures must be verified in TARIC.

Organic substances under CN code 2904 20 (nitro and nitroso derivatives) require detailed chemical documentation for customs clearance. The Safety Data Sheet must comply with REACH Annex II. Substances classified as hazardous under CLP require GHS pictogram labelling. Transport follows ADR (road) or IMDG (maritime) regulations. Some organic substances may be subject to export controls as dual-use goods. Importers should verify whether the substance requires REACH authorisation (Annex XIV) or is subject to restrictions (Annex XVII).