Other

CN code 391290 covers cellulose and its chemical derivatives, not elsewhere specified, in primary forms. This is a residual subheading for cellulose derivatives not classified under CN 391211-391239. Products include cellulose propionates (CAP), cellulose butyrates (CAB), microcrystalline cellulose (MCC), regenerated cellulose in powder form, and other esters and mixed ester-ethers of cellulose. Cellulose acetate propionate (CAP) and cellulose acetate butyrate (CAB) are used in coatings, lacquers and optical products. Microcrystalline cellulose (MCC) is widely used as a pharmaceutical excipient and as food additive E460.

Cellulose derivatives classified under CN 391290 are subject to REACH regulation. As polymers they are exempt from registration, but substances used in the chemical modification of cellulose may require ECHA registration. Microcrystalline cellulose (E460) must meet the specifications of Regulation (EU) No 231/2012 as a food additive. CAP and CAB intended for food contact materials must comply with Regulation (EU) No 10/2011. Pharmaceutical cellulose derivatives are subject to European Pharmacopoeia requirements. The Safety Data Sheet should address specific hazards associated with the particular cellulose derivative, including solvent and residual monomer content.

Customs declarations for cellulose derivatives under CN 391290 should specify the derivative type (CAP, CAB, MCC), physical form, degree of modification and intended use. Given the residual nature of this subheading, customs authorities may require documentation confirming that the goods do not qualify for more specific subheadings of heading 3912. Binding Tariff Information ruling is recommended for products with uncertain classification. Imports of cellulose derivatives into the EU come primarily from the United States, China, Japan and India. Preferential duty rates may be available under FTA agreements. Verification of rates in TARIC before transacting is recommended.

Other cellulose derivatives classified under CN code 3912 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.