32049000
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
Other
Classification and scope of CN code 320490
CN code 320490 covers mixtures of synthetic organic colouring matter and preparations based on two or more colouring matter from subheadings 3204.11 to 3204.19, as well as mixtures of these products with luminophores from subheading 3204.20. This heading is a broad residual code for multi-component preparations used in the textile, paper, plastics, and printing industries. Classification requires identification that the product is a mixture of at least two different colouring matters or constitutes a ready-to-use preparation containing more than one colouring component. Import documentation should include full composition specification.
REACH, CLP requirements and safety regulations
Mixtures of synthetic colouring matter are subject to full REACH and CLP requirements. Each component of the mixture must be individually registered with ECHA. CLP labelling must account for the classification of all hazardous components present above classification thresholds. The Safety Data Sheet must be prepared for the mixture as a whole and contain information on all hazardous components. Mixtures containing azo dyes must be tested for release of prohibited arylamines. Transport of liquid mixtures may be subject to ADR regulations depending on the hazard class.
Practical import aspects
Customs declarations for dye mixtures under CN code 320490 should include full qualitative and quantitative composition, CAS numbers of main components, and intended use. Classification of mixtures may be more complex than individual dyes, so preliminary consultation with customs authorities or obtaining a Binding Tariff Information (BTI) is recommended. Importers may benefit from EU tariff preferences. Quality control includes full composition analysis, arylamine testing, and heavy metal analysis.
VOC standards and emission limits
When importing Other synthetic colouring matter mixtures (CN 3204 90) 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.
Frequently asked questions
When is a dye mixture classified under code 320490?
A mixture is classified under code 320490 when it contains two or more synthetic organic colouring matters from different subheadings 3204.11-3204.20. If the mixture contains dyes of only one type, it is classified under the corresponding subheading for that type.
Does the SDS for a dye mixture differ from that for a single dye?
Yes, the SDS for a mixture must account for all hazardous components above CLP classification thresholds. It must contain full composition information, hazards arising from component interactions, and exposure scenarios for the entire mixture, not just individual substances.
Is it advisable to obtain a BTI for dye mixtures?
Yes, a Binding Tariff Information is particularly useful for dye mixtures as their classification can be ambiguous. A BTI provides legal certainty regarding the CN code for 3 years and is recognised in all EU Member States.
What VOC limits apply to paints and coatings CN 3204 90?
Paints and coatings under CN code 3204 90 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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