CN code 320190 covers other vegetable tanning extracts not classified under other subheadings of heading 3201. This includes tannins and their salts, ethers, esters, and other derivatives, used primarily in the leather tanning industry, as well as in the manufacture of inks, dyes, and pharmaceutical preparations. These extracts are obtained from oak bark, quebracho, mimosa, sumac, and other plants rich in polyphenols. Correct classification requires proper identification of the chemical composition and confirmation that the product is not a finished tanning preparation classified elsewhere. Customs clearance documentation should include technical specifications indicating the active substance content, product form, and intended industrial use.

Importing tanning extracts into the European Union is subject to the REACH Regulation (EC No 1907/2006). The importer must ensure that the imported substance is registered with ECHA in the appropriate tonnage band or that an Only Representative has been appointed. Tanning extracts must be labelled in accordance with the CLP Regulation (EC No 1272/2008), and the supplier is obliged to provide a Safety Data Sheet (SDS) prepared according to Regulation (EU) 2020/878. Some plant extracts may contain allergenic or irritant substances, requiring appropriate hazard pictogram labelling. Transport must comply with ADR regulations, particularly for solutions in organic solvents. These substances are not subject to CBAM regulation.

Customs declarations for goods under CN code 320190 should include the product chemical specification, CAS number of the main active substance, tannin concentration, and commercial form (powder, granules, solution). Export of tanning extracts may require verification under the EU Dual-Use Regulation (EU) 2021/821, although most products in this group are not on control lists. Importers may benefit from preferential duty rates under free trade agreements or the GSP system, provided proper origin documentation is presented. Verification of applicable rates in the TARIC database is recommended before completing transactions. Phytosanitary controls may apply to extracts containing plant fragments.

When importing Vegetable tanning extracts (CN 3201 90) 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. Conformity testing may include spectrometric analysis for composition verification.