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29051600
ORGANIC CHEMICALSAlkohole alifatyczne i ich fluorowcowane, sulfonowane, nitrowane lub nitrozowane pochodne

Octanol (octyl alcohol) and isomers thereof

Product description and tariff classification

CN code 290516 covers octanol and its isomers, most notably 2-ethylhexanol (CAS 104-76-7), by far the most commercially significant substance in this subheading. 2-Ethylhexanol is produced industrially via the hydroformylation of propylene (oxo process) to butyraldehydes, followed by aldol condensation and hydrogenation. It is the primary feedstock for the manufacture of PVC plasticisers, including di(2-ethylhexyl) phthalate (DEHP) as well as phthalate-free alternatives such as DINP and DIDP. Classification under Note 1 to Chapter 29 of the Combined Nomenclature requires the substance to be in chemically pure form or as an aqueous solution — technical C8 alcohol blends typically require separate classification analysis and may fall under different tariff headings. Customs documentation must include the CAS number, chemical purity confirmed by a Certificate of Analysis (COA) with GC or spectroscopic data, and the manufacturer specification sheet. The substance is typically transported in bulk road tankers or rail tank wagons and, less frequently, in IBC containers. Correct tariff classification is essential to determine the applicable duty rate — current MFN rates and any preferential measures should always be verified in the European Commission TARIC database before each import transaction. Where doubt exists regarding classification, a Binding Tariff Information (BTI) ruling from the competent customs authority provides legal certainty for a period of three years throughout the EU.

REACH, CLP and chemical safety requirements

Imports of 2-ethylhexanol and other octanol isomers into the EU are subject to full REACH requirements (Regulation EC No 1907/2006). The substance must carry a valid ECHA registration covering the tonnage band that corresponds to the actual annual import volume. Non-EU manufacturers are advised to appoint an Only Representative (OR) established in the EU, who assumes full registration responsibilities and manages communication through the supply chain in accordance with Article 8 of REACH. Packaging and tanker labelling must comply with the CLP Regulation (EC No 1272/2008) — 2-ethylhexanol is classified as Acute Tox. 4 (oral) and as a skin and eye irritant. A current Safety Data Sheet (SDS) prepared in accordance with Regulation (EU) 2020/878 and covering exposure scenarios for all identified uses must be supplied in the official language of the destination country with every delivery to professional recipients. Downstream plasticisers derived from 2-ethylhexanol, in particular DEHP, are subject to REACH restrictions (Annex XVII) and the authorisation requirement, which must be factored into supply chain planning and contractual due diligence. Road transport is governed by ADR Class 3 provisions as a flammable liquid. Storage areas require forced ventilation and anti-spark electrical installations in line with ATEX requirements.

Practical guidance for importers and exporters

The customs declaration for octanol imports under CN 290516 must state the CAS number, degree of purity, production process (synthetic vs. bio-based) and net weight in kilograms. Customs authorities may request the Certificate of Analysis to verify the declared chemical purity. For bio-based 2-ethylhexanol derived from biomass fermentation routes, it is necessary to verify whether the correct classification differs, as natural fatty alcohols may fall under separate CN codes. Check whether a Free Trade Agreement (FTA) between the EU and the country of export or the Generalised Scheme of Preferences (GSP or GSP+) provides a preferential duty rate requiring an EUR.1 movement certificate or an invoice declaration issued by a registered exporter under the REX system. Exports from the EU to third countries require sanctions screening and, where applicable, end-use verification. Importers should retain REACH and SDS documentation for at least 10 years. Any changes in the chemical composition of imported batches require an SDS update and downstream user notification. Where classification is uncertain, apply for a Binding Tariff Information (BTI) ruling from the competent customs authority — a BTI is valid for three years across the entire EU.

Chemical safety and SDS requirements

Organic substances under CN code 2905 16 (Octanol and isomers) 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).

Frequently asked questions

Does 2-ethylhexanol require REACH registration for import into the EU?
Yes. 2-Ethylhexanol (CAS 104-76-7) is imported in large volumes, which triggers mandatory REACH registration with ECHA in the tonnage band matching the actual annual import volume. Non-EU manufacturers may appoint an Only Representative (OR) established in the EU to assume registration obligations under Article 8 of REACH. Without a valid registration, the substance cannot legally be placed on the EU market. A current Safety Data Sheet (SDS) prepared in accordance with Regulation (EU) 2020/878 must accompany every delivery to professional recipients and must be made available to downstream users on request, free of charge.
How should bio-based C8 alcohol be classified — CN 290516 or Chapter 22?
Classification depends on the chemical nature of the substance, not on its production method. Chemically pure 1-octanol or 2-ethylhexanol, regardless of whether it is produced petrochemically or derived from biomass fermentation, is classified under CN 290516 as a chemical product of Chapter 29. Fermentation-derived C8 alcohol blends of undefined isomeric composition may fall outside Chapter 29. Natural fatty alcohols derived from coconut or palm oil with a C8 chain length may be classified differently. In cases of doubt, a Binding Tariff Information (BTI) ruling from the competent customs authority provides legally binding classification certainty for three years.
Can DEHP derived from 2-ethylhexanol be freely imported into the EU?
No. Di(2-ethylhexyl) phthalate (DEHP) is listed in Annex XIV of REACH as a substance of very high concern (SVHC) due to its endocrine-disrupting properties. The import and use of DEHP in the EU requires an authorisation granted by the European Commission, or the activity must fall within the scope of a granted use exemption under Article 56 of REACH. The precursor 2-ethylhexanol is treated separately, but the entire supply chain must be documented in accordance with REACH communication obligations. Restrictions also apply to articles containing DEHP above 0.1 percent by weight. A current SDS covering relevant exposure scenarios must be maintained throughout the supply chain.
How to classify Octanol and isomers in customs tariff 2905 16?
Classification of Octanol and isomers under CN code 2905 16 is based on chemical structure and functional groups. If in doubt, you can apply for a Binding Tariff Information (BTI) from the national customs authority.