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32041600
TANNING OR DYEING EXTRACTS; TANNINS AND THEIR DERIVATIVES; DYES, PIGMENTS AND OTHER COLOURING MATTER; PAINTS AND VARNISHES; PUTTY AND OTHER MASTICS; INKSSynthetic 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

Reactive dyes and preparations based thereon

Classification and characteristics of reactive dyes

CN code 320416 covers reactive dyes and preparations based thereon. Reactive dyes form a covalent bond with the fibre, ensuring exceptional dyeing permanence. They are used primarily for dyeing cotton, viscose, and other cellulosic fibres, as well as wool and silk. They constitute the largest group of dyes used in the textile industry by volume. Reactive dyes contain reactive groups such as monochlorotriazine, dichlorotriazine, or vinyl sulphone. Classification under code 320416 requires confirmation of the reactive dyeing mechanism as defined in Note 3 to Chapter 32 of the Combined Nomenclature.

REACH, CLP requirements and safety

Import of reactive dyes is subject to full REACH requirements. Each substance must be registered with ECHA. Reactive azo dyes may release prohibited arylamines and are subject to Annex XVII REACH restrictions. Many reactive dyes are classified as respiratory sensitisers (H334) due to their ability to cause occupational asthma, which is a significant hazard for dye house workers. CLP labelling must reflect this classification. The Safety Data Sheet must contain detailed exposure scenarios. Transport in powder form requires protection from moisture and dusting.

Trade and import procedures

Customs declarations for reactive dyes under CN code 320416 should include the Colour Index, CAS number, concentration, and intended use. Reactive dyes are one of the most dynamic segments of the dye market, with growing imports from China, India, and Turkey. Importers may benefit from GSP tariff preferences or trade agreements. Quality control is crucial and includes testing for arylamines, heavy metals, purity, and specification compliance. Reactive dyes are not subject to dual-use export controls.

VOC standards and emission limits

When importing Reactive dyes and preparations (CN 3204 16) 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

Why can reactive dyes cause occupational asthma?
Reactive dyes contain chemical groups capable of bonding with human body proteins, which can lead to respiratory sensitisation. Reactive dye dust is a recognised occupational allergen. Workers exposed to dust should use filter masks and work in ventilated spaces.
What is the difference between reactive and direct dyes?
Direct dyes (code 320414) bind to fibres through physical interactions, while reactive dyes (code 320416) form a covalent bond with the fibre. This gives reactive dyes significantly better wash and light fastness properties.
Are reactive dyes subject to REACH arylamine restrictions?
Yes, reactive azo dyes releasing prohibited arylamines from entry 43 of Annex XVII REACH cannot be used in textile and leather articles. Arylamine testing according to EN 14362 is a standard quality control requirement for imported reactive dyes.
What VOC limits apply to paints and coatings CN 3204 16?
Paints and coatings under CN code 3204 16 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.