32041200
TANNING OR DYEING EXTRACTS; TANNINS AND THEIR DERIVATIVES; DYES, PIGMENTS AND OTHER COLOURING MATTER; PAINTS AND VARNISHES; PUTTY AND OTHER MASTICS; INKS›Synthetic organic colouring matter, whether or not chemically defined; preparations as specified in note 3 to this chapter based on synthetic organic colouring matter; synthetic organic products of a kind used as fluorescent brightening agents or as luminophores, whether or not chemically defined
Acid dyes, whether or not premetallised, and preparations based thereon; mordant dyes and preparations based thereon
Characteristics and classification of acid dyes
CN code 320412 covers acid dyes and preparations based thereon, used mainly for dyeing protein fibres (wool, silk) and polyamide fibres (nylon). Acid dyes are sodium salts of sulfonic or carboxylic acids with complex aromatic structures and show good water solubility in acidic media. They are also used in the food industry as food colourants, in cosmetics, and in medical diagnostics. Classification requires confirmation of the chemical character of the dye and its belonging to the acid dye group as defined in Note 3 to Chapter 32. Preparations include ready-to-use acid dye mixtures.
REACH, CLP regulations and safety requirements
Import of acid dyes is subject to full REACH requirements. Substances must be registered with ECHA, and the importer is required to hold a current Safety Data Sheet. Acid dyes used as food additives are additionally subject to Regulation (EC) No 1333/2008 and must have EFSA authorisation. Acid azo dyes releasing prohibited arylamines are subject to Annex XVII REACH restrictions. CLP labelling must account for all hazards including sensitising and irritant effects. Transport of acid dye solutions is subject to ADR regulations depending on solvent composition and concentration.
Trade and customs procedures
Customs declarations for acid dyes under CN code 320412 should include the Colour Index number, CAS number, active substance concentration, and intended product use. For food-grade dyes, additional certification of compliance with the food additives regulation is required. Importers may benefit from EU tariff preferences, including agreements with Turkey, South Korea, and Japan. Export of acid dyes may require dual-use verification, although most products are not on control lists. Import quality control includes testing for heavy metals, arylamines, and dye purity.
VOC standards and emission limits
When importing Acid dyes and preparations (CN 3204 12) 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.
Frequently asked questions
Are food-grade acid dyes classified under CN code 320412?
Yes, acid dyes used as food additives may be classified under CN code 320412, provided they are synthetic organic colouring matter. Additionally, they must comply with Regulation (EC) No 1333/2008 on food additives and hold an E number assigned by EFSA.
What restrictions apply to acid azo dyes?
Acid azo dyes releasing prohibited arylamines listed in entry 43 of Annex XVII of REACH cannot be used in textile and leather articles. The list includes 22 arylamines, including benzidine and 4-aminobiphenyl. Testing for arylamines is standard in import quality control.
Does import of acid dyes from India benefit from tariff preferences?
India benefits from the EU GSP system. Acid dyes under CN code 320412 may qualify for preferential duty rates, provided a Form A certificate of origin or appropriate invoice declaration is presented. Current rates should be verified in the TARIC database.
What VOC limits apply to paints and coatings CN 3204 12?
Paints and coatings under CN code 3204 12 are subject to VOC limits per Directive 2004/42/EC. Matt decorative paints: max 30 g/l, gloss decorative paints: max 100-150 g/l, industrial coatings: limits vary by application.
Useful tools & resources
Customs calculators
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