39021000
PLASTICS AND ARTICLES THEREOF›Polymers of propylene or of other olefins, in primary forms
Polypropylene
Product characteristics and tariff classification
CN code 390210 covers polypropylene (PP) in primary forms. Polypropylene is a thermoplastic polymer produced by polymerisation of propylene using Ziegler-Natta or metallocene catalysts. PP exists in three stereoisomeric forms: isotactic, syndiotactic and atactic, of which isotactic has the greatest industrial significance. Products classified under this code include propylene homopolymer in the form of granules, powder or paste. PP is characterised by low density (approximately 0.90-0.91 g/cm3), good chemical resistance, high softening point and excellent processing properties. For customs classification, it is important to distinguish propylene homopolymer (code 390210) from propylene copolymers (codes 390230, 390290) based on the manufacturer's technical specification.
EU regulatory requirements for import
Polypropylene imported into the EU is subject to REACH (EC No 1907/2006) regarding monomers and additive substances. Catalyst residues in the polymer, including titanium and magnesium compounds, should be documented in the technical data sheet. PP intended for food contact must comply with Regulation (EU) No 10/2011, including migration limits for monomers and additives. Polypropylene is one of the most widely used polymers in food packaging, making food safety requirements of key commercial importance. The SUP Directive (EU) 2019/904 affects the single-use PP packaging segment. Importers should consider obligations under Extended Producer Responsibility (EPR) in the destination member state.
International trade and customs procedures
When importing polypropylene under CN code 390210, customs documentation should include a technical specification covering MFI, isotacticity, density and commercial form. Polypropylene is the second most widely produced polymer globally after polyethylene, with annual production exceeding 80 million tonnes. Major PP exporters include Middle Eastern countries, China, South Korea and India. Duty rates on PP imported into the EU should be verified in the TARIC system, as preferences under FTA agreements or the GSP system may apply. PP imports from certain countries may be subject to trade defence measures. EU exporters should check customs and regulatory requirements of the destination country, as they may differ significantly from EU standards.
Properties of Polypropylene PP and trade applications
Polypropylene PP classified under CN code 3902 10 are polymers in primary forms (granules, powder, liquid, block) imported as feedstock for plastics processing. Import requires REACH registration, Safety Data Sheets and technical specifications including molecular weight, density and melt flow index (MFI). Products intended for food contact must comply with Regulation (EU) 10/2011 and be listed on the positive monomer list.
Frequently asked questions
How to distinguish PP homopolymer from PP copolymer for classification?
Propylene homopolymer (code 390210) is a polymer consisting exclusively of propylene units. Propylene copolymers, e.g. with ethylene (PP-random or PP-block), are classified under codes 390230 or 390290. Distinguishing between them requires the manufacturer's technical specification indicating the polymer composition. In case of doubt, customs authorities may require laboratory analysis.
Does food-contact PP require special testing?
Yes. Polypropylene for food contact must meet the requirements of Regulation (EU) No 10/2011, including global and specific migration testing conducted in accordance with EN standards. The manufacturer is required to issue a declaration of compliance. Substances used in PP must be listed on the positive list in Annex I to the regulation.
Is polypropylene subject to the CBAM mechanism?
No. Polypropylene and other plastics from Chapter 39 are not covered by CBAM (Carbon Border Adjustment Mechanism). CBAM in its current form applies only to products from high CO2-intensity sectors such as steel, aluminium, cement, fertilisers, hydrogen and electricity. Plastics have not been included in this mechanism.
What technical specifications are needed for import of CN 3902 10?
Import of CN 3902 10 requires specifications: molecular weight, density, MFI, comonomer composition. SDS and REACH registration above 1 tonne/year are mandatory. For food-contact applications, compliance with Regulation (EU) 10/2011 is required.
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