29337900
ORGANIC CHEMICALS›Heterocyclic compounds with nitrogen hetero-atom(s) only
Other lactams
Scope and key substances of subheading 293379
CN subheading 293379 covers other lactams - cyclic amides that are internal esters of amino acids - not classified in more specific subheadings of heading 2933. Lactams are the key industrial monomers for polyamide (PA) production. The most important substances classified here include: caprolactam (epsilon-caprolactam, CAS 105-60-2) - the monomer for polyamide 6 (PA6, nylon 6), used in the production of fibres, films, engineering plastics and coatings; laurolactam (omega-laurolactam, CAS 947-04-6) - the monomer for polyamide 12 (PA12), used in demanding engineering applications, fuel lines, medical implants and 3D printing (SLS powder); and other seven- to fourteen-membered lactams used in the synthesis of speciality copolyamides. Caprolactam is produced on a very large industrial scale via Beckmann rearrangement of cyclohexanone oxime in oleum or sulfuric acid - it is one of the most important petrochemical feedstocks in the world, with global production exceeding five million tonnes per year. Laurolactam is manufactured from cyclododecanone via oxime synthesis and Beckmann rearrangement. PA12 from laurolactam is characterised by exceptional chemical resistance, low moisture absorption and flexibility at low temperatures.
REACH and CLP regulatory framework for caprolactam and laurolactam
Substances from subheading 293379 imported into the European Union are subject to REACH Regulation (EC) No 1907/2006. Caprolactam holds an active ECHA registration and is classified under CLP Regulation (EC) No 1272/2008 as irritating to the skin and eyes (H315, H319) and harmful if inhaled (H332). It is not listed on the SVHC Candidate List and is not subject to REACH authorisation. Laurolactam holds a REACH registration and is classified as a skin irritant (H315) and eye irritant (H319). Both substances are transported as solids in granule, flake or powder form and are not classified as ADR dangerous goods under standard transport conditions. Safety Data Sheets (SDS) must be prepared in accordance with Annex II of Regulation (EU) 2020/878 and provided to professional recipients. Caprolactam used in food-contact packaging made of PA6 is subject to Regulation (EU) No 10/2011; a specific migration limit for caprolactam applies to food-contact applications. Importers should monitor the ECHA CoRAP database for any new substance evaluations concerning higher lactams.
Customs procedures and import documentation for CN 293379
Importing goods under subheading 293379 requires an electronic customs declaration with the correct 8-digit CN or TARIC code. Documentation should include a commercial invoice with the full chemical name and CAS number, a technical specification or certificate of analysis (CoA) with declared purity and quality parameters (moisture content, viscosity, melting point), a Safety Data Sheet (SDS) in the language of the importing country, a transport document and a packing list. Caprolactam is transported in bulk in tank wagons or in intermediate bulk containers (IBCs); when transported in the molten state (melting point approximately 70 degrees Celsius) specialised isothermal tankers are required. Laurolactam is transported in big-bags, sacks or containers as granules. Import of caprolactam is subject to market surveillance given significant production capacity in Asia - importers should regularly check the TARIC database for any trade protection or anti-dumping measures applicable to imports from specific countries. Current MFN and preferential tariff rates under EU free trade agreements must be verified in the TARIC system. Preferential tariff treatment requires submission of a valid proof of preferential origin - an EUR.1 movement certificate or an exporter's declaration under the REX system.
Chemical safety and SDS requirements
Organic substances under CN code 2933 79 (Other lactams) require detailed chemical documentation for customs clearance. The Safety Data Sheet must comply with REACH Annex II. Substances classified as hazardous under CLP require GHS pictogram labelling. Transport follows ADR (road) or IMDG (maritime) regulations. Some organic substances may be subject to export controls as dual-use goods. Importers should verify whether the substance requires REACH authorisation (Annex XIV) or is subject to restrictions (Annex XVII). A Certificate of Analysis confirming purity and composition is recommended.
Frequently asked questions
How is caprolactam distinguished from polyamide PA6 for CN classification purposes?
Caprolactam (CAS 105-60-2) as a monomer - a single, chemically defined organic compound - is classified under CN 293379 regardless of its intended end use. Polyamide 6 (PA6) as the polymerisation product of caprolactam is classified in Chapter 39 (plastics and articles thereof) or Chapters 54 and 55 (man-made continuous or staple fibres) depending on the physical form and degree of processing. The classification criterion is the degree of polymerisation and the physical form of the product, not the declared end use. Importers of intermediate or partially polymerised products, or of caprolactam-PA6 blends, should consider applying for Binding Tariff Information (BTI) ruling to avoid misclassification, which can result in customs debt and penalty proceedings.
Is caprolactam in PA6 food-contact packaging subject to migration limits?
Yes. Caprolactam is listed in Regulation (EU) No 10/2011 on plastic materials and articles intended to contact food. A specific migration limit (SML) of 15 mg/kg of food applies to caprolactam; this substance is routinely monitored by market surveillance authorities due to its potential to migrate from PA6 food-contact packaging. Importers of PA6 articles for food contact - packaging, trays, laminates - must hold a declaration of conformity issued by the manufacturer and migration test results confirming compliance with the SML. Infringement of the migration limit may lead to goods being detained by border control authorities or notified to the RASFF early warning system. Non-compliant packaging articles may not be placed on the EU market.
What technical documentation is needed when importing laurolactam for medical or automotive use?
Laurolactam (CAS 947-04-6) used to produce PA12 for medical applications - implants, catheter tubing, membranes - requires technical documentation confirming conformity with biocompatibility standards (ISO 10993) and EU Medical Devices Regulation (EU) 2017/745 MDR requirements. For automotive fuel and brake line applications, conformity with SAE J844 and DIN 73378 must be demonstrated. Customs documentation should include the commercial invoice with the CAS number, CoA, SDS and an end-use specification. The applicable 10-digit TARIC code for laurolactam and current MFN tariff rates, along with any preferential rates under EU free trade agreements, must always be verified in the TARIC database of the European Commission before completing the import declaration.
How to classify Other lactams in customs tariff 2933 79?
Classification of Other lactams under CN code 2933 79 is based on chemical structure and functional groups. If in doubt, you can apply for Binding Tariff Information (BTI) from the national customs authority.
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