32041400
TANNING OR DYEING EXTRACTS; TANNINS AND THEIR DERIVATIVES; DYES, PIGMENTS AND OTHER COLOURING MATTER; PAINTS AND VARNISHES; PUTTY AND OTHER MASTICS; INKS›Synthetic organic colouring matter, whether or not chemically defined; preparations as specified in note 3 to this chapter based on synthetic organic colouring matter; synthetic organic products of a kind used as fluorescent brightening agents or as luminophores, whether or not chemically defined
Direct dyes and preparations based thereon
Tariff classification and characteristics of direct dyes
CN code 320414 covers direct (substantive) dyes and preparations based thereon, used primarily for dyeing cellulose, cotton, viscose, and paper. Direct dyes are sodium salts of polyaromatic azo compounds that have the ability to bind directly to cellulose fibres without the need for a mordant. They are characterised by good water solubility and ease of application, making them a popular choice in the textile and paper industries. Classification under code 320414 requires confirmation of the substantive character of the dye as defined in Note 3 to Chapter 32 of the Combined Nomenclature. Import of these products requires technical documentation.
REACH, CLP requirements and safety regulations
Direct dyes imported into the EU are subject to the REACH Regulation (EC No 1907/2006). The importer must ensure registration of each substance with ECHA. Particular attention must be paid to direct azo dyes that may release prohibited arylamines, which are subject to entry 43 of Annex XVII REACH restrictions. Some benzidine-based direct dyes (e.g. Direct Red 28, Congo Red) are classified as carcinogenic and subject to strict restrictions. CLP labelling must reflect full hazard classification. A Safety Data Sheet is required and must be current. Transport of dyes in solid form is subject to less restrictive ADR requirements than solutions.
International trade and customs procedures
Customs declarations for direct dyes under CN code 320414 should include the Colour Index, CAS number, concentration, and intended use. Importers should verify whether the dye is on the list of prohibited substances in textile articles. Tariff preferences are available under EU trade agreements, including with Southeast Asian and Latin American countries. Quality control of imported direct dyes should include testing for arylamines, heavy metals, and dye purity. Export is not subject to special restrictions unless the product is classified as dual-use.
VOC standards and emission limits
When importing Direct dyes and preparations (CN 3204 14) into the EU, VOC content regulations under Directive 2004/42/EC must be considered. Decorative paints and automotive refinish products have established VOC limits. CLP classification requires appropriate GHS pictogram labelling on packaging. Pigments containing heavy metals (lead, cadmium, chromium VI) are subject to strict REACH restrictions (Annex XVII). Importers must have SDS sheets and ensure labelling complies with destination country regulations. Conformity testing may include spectrometric analysis for composition verification.
Frequently asked questions
Can Congo Red dye be imported into the EU?
Congo Red (Direct Red 28, CI 22120) releases the prohibited arylamine benzidine and is therefore subject to Annex XVII REACH restrictions. It may be imported as a laboratory reagent but cannot be used for dyeing textile and leather articles intended for human skin contact.
Which fibres are direct dyes used for?
Direct dyes are primarily intended for dyeing cellulosic fibres such as cotton, linen, viscose, and modal. They are also used for paper dyeing and to a lesser extent silk. They are unsuitable for dyeing synthetic fibres like polyester, for which disperse dyes are used.
What quality tests are required for imported direct dyes?
Standard tests include dye purity determination, heavy metal content analysis (Pb, Cd, Hg, Cr VI), testing for release of prohibited arylamines according to EN 14362, and verification of compliance with trade specification. Test results should be available to customs authorities upon request.
What VOC limits apply to paints and coatings CN 3204 14?
Paints and coatings under CN code 3204 14 are subject to VOC limits per Directive 2004/42/EC. Matt decorative paints: max 30 g/l, gloss decorative paints: max 100-150 g/l, industrial coatings: limits vary by application.
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