32061900
TANNING OR DYEING EXTRACTS; TANNINS AND THEIR DERIVATIVES; DYES, PIGMENTS AND OTHER COLOURING MATTER; PAINTS AND VARNISHES; PUTTY AND OTHER MASTICS; INKS›Other colouring matter; preparations as specified in note 3 to this chapter, other than those of heading 3203, 3204 or 3205; inorganic products of a kind used as luminophores, whether or not chemically defined
Other
Classification scope and characteristics
CN code 320619 covers other pigments and preparations based on titanium dioxide not falling under subheading 320611, i.e. those with TiO2 content below 80 percent by weight on dry matter or constituting preparations with other pigments or fillers. This includes TiO2 slurries (aqueous suspensions), pigment dispersions, and TiO2 pigments coated with silicon or aluminium oxides to improve dispersibility and weathering resistance. These products are used in paints, plastics, paper, and cosmetics. Import documentation should clearly indicate the TiO2 content for correct classification.
REACH, CLP requirements and safety
TiO2-based pigment preparations under code 320619 are subject to full REACH and CLP requirements. The classification of TiO2 as a suspected carcinogen category 2 (H351) by inhalation also applies to preparations containing TiO2 in dust form. Mixtures containing TiO2 must be labelled according to CLP mixture classification rules, considering concentration thresholds. The Safety Data Sheet must be prepared for the entire preparation. Nano forms of TiO2 are subject to additional safety assessment requirements, particularly in cosmetics and food contact materials.
Trade and import practice
Import of TiO2 preparations under code 320619 requires full product specification including TiO2 content, additional components, physical form, and intended use. Correct distinction between codes 320611 and 320619 is crucial due to different duty rates. Importers may benefit from EU tariff preferences. The TiO2 preparations market includes pigment concentrates, slurries, and masterbatches, with major suppliers from Europe, China, and the USA.
VOC standards and emission limits
When importing Other TiO2-based pigments and preps (CN 3206 19) 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 TiO2 pigment classified under 320619 instead of 320611?
Code 320619 applies when TiO2 content is below 80 percent by weight on dry matter or when the product is a preparation with other components. TiO2 slurry in aqueous suspension is also classified under 320619. Classification requires documentation of TiO2 content.
Is nano-TiO2 subject to additional regulations?
Yes, the nano form of TiO2 is subject to specific requirements. In cosmetics, nano-TiO2 must undergo safety assessment and be labelled as nano on the label. In food contact materials, it requires a separate EFSA assessment. Appropriate CLP labelling is also required.
What information must the SDS for a TiO2 preparation contain?
The SDS must include information on TiO2 classification as Carc. 2 H351 (by inhalation), respiratory protection measures, occupational exposure limits, and exposure scenarios. It must also include information on all other hazardous components of the preparation.
What VOC limits apply to paints and coatings CN 3206 19?
Paints and coatings under CN code 3206 19 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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