CN code 390690 covers acrylic polymers in primary forms other than polymethyl methacrylate (PMMA). This residual heading includes polyacrylates (e.g. polybutyl acrylate, polyethyl acrylate, poly-2-ethylhexyl acrylate), polymethacrylates other than PMMA, acrylic copolymers, polyacrylic acid (PAA), polyacrylamide (PAM) and acrylic resins used as binders in paints and lacquers. Acrylic dispersions are among the most important binders in modern emulsion paints. Products come as granules, powder, aqueous dispersions, solutions or emulsions. Classification requires demonstrating that the polymer is an acrylic or methacrylic polymer other than PMMA.
Regulatory requirements
Acrylic polymers imported under code 390690 are subject to REACH regarding monomers and additive substances. Acrylates (butyl acrylate, ethyl acrylate) are substances with CLP classification as flammable and irritant. Acrylic acid is a corrosive substance. Polyacrylamide PAM requires control of residual acrylamide monomer, which is carcinogenic Category 1B and mutagenic. Acrylic dispersions may contain preservatives subject to the Biocidal Products Regulation. Acrylic polymers for food contact must comply with Regulation (EU) No 10/2011. Acrylic resins in paints are subject to the VOC Directive. The importer should have an SDS and technical documentation identifying the base monomer.
Trade and customs procedures
When importing acrylic polymers under CN code 390690, customs documentation should include polymer identification (monomer type), commercial form, molecular weight and any solvent or water content. Duty rates should be verified in the TARIC system. Acrylic dispersions represent a significant segment of the polymer binder market, with major producers including BASF, Dow, Arkema (Encorex), Wacker and Celanese. The acrylic polymer market is diversified due to the broad range of monomers and applications. Transport of aqueous dispersions requires freeze protection. Polymers in organic solutions are subject to ADR Class 3.
Properties of Other acrylic polymers and trade applications
Other acrylic polymers classified under CN code 3906 90 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
What is the difference between polyacrylates and polymethacrylates?
Polyacrylates are derived from acrylic acid monomers (CH2=CHCOOR), while polymethacrylates from methacrylic acid monomers (CH2=C(CH3)COOR). Polymethacrylates including PMMA (code 390610) are harder and more brittle. Polyacrylates (code 390690) are more flexible and used mainly as binders in paints and adhesives.
Do acrylic dispersions for paints require special documentation?
Acrylic dispersions used as paint binders require a Technical Data Sheet (TDS) and may require an SDS due to preservative content. Paints containing these dispersions are subject to the VOC Directive (2004/42/EC). The dispersion itself is classified under code 390690 as an acrylic polymer in primary form.
Does polyacrylamide PAM require special control?
Yes. Polyacrylamide requires strict control of residual acrylamide monomer content, which is carcinogenic Category 1B and mutagenic Category 1B. PAM for drinking water treatment is subject to particularly stringent residual acrylamide limits established by water quality directives. A certificate of analysis is essential.
What technical specifications are needed for import of CN 3906 90?
Import of CN 3906 90 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.