32061100
TANNING OR DYEING EXTRACTS; TANNINS AND THEIR DERIVATIVES; DYES, PIGMENTS AND OTHER COLOURING MATTER; PAINTS AND VARNISHES; PUTTY AND OTHER MASTICS; INKS›Other colouring matter; preparations as specified in note 3 to this chapter, other than those of heading 3203, 3204 or 3205; inorganic products of a kind used as luminophores, whether or not chemically defined
Pigments and preparations based on titanium dioxide - Containing 80 % or more by weight of titanium dioxide calculated on the dry matter
Tariff classification of TiO2 pigments
CN code 320611 covers pigments based on titanium dioxide containing at least 80 percent by weight of TiO2 calculated on the dry matter. Titanium dioxide is the most widely used white pigment globally, employed in the manufacture of paints, coatings, plastics, paper, and cosmetics. TiO2 pigments exist in two main crystalline forms: rutile (most common, thermally stable) and anatase (used mainly in paper and fibres). Classification under code 320611 requires a minimum TiO2 content of 80 percent. Pigments with lower content or preparations with other components may be classified under subheading 320619. Import documentation should include an analytical certificate stating the crystalline form and TiO2 content.
REACH, CLP regulations and TiO2 classification
Titanium dioxide was classified in the EU as a suspected carcinogen category 2 by inhalation (H351) under the 14th ATP to the CLP Regulation, applicable since 2021. The classification applies to TiO2 in powder form containing at least 1 percent of particles with an aerodynamic diameter below 10 micrometres. Import of TiO2 pigments is subject to full REACH requirements including ECHA registration. The Safety Data Sheet must reflect the new CLP classification and appropriate protective measures. TiO2 pigments used in cosmetics must be listed in Annex IV of the Cosmetics Regulation, with restrictions for the nano form.
Trade and import aspects
The TiO2 pigment market is one of the largest pigment segments, with annual global production of approximately 8 million tonnes. Major producers include Chemours, Tronox, Kronos, Venator, and Lomon Billions. Imports from China may be subject to anti-dumping duties established by the European Commission. Import documentation should include an analytical certificate, SDS, origin documents, and technical specification. Tariff preferences may be available under EU trade agreements. Quality control includes determination of TiO2 content, crystalline form, particle size distribution, and trace metal content.
VOC standards and emission limits
When importing Titanium dioxide pigments min. 80% TiO2 (CN 3206 11) 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.
Frequently asked questions
Is titanium dioxide classified as carcinogenic in the EU?
TiO2 was classified as a suspected carcinogen category 2 (H351) by inhalation only, under the 14th ATP to CLP. The classification applies to powder with particles below 10 micrometres. It does not apply to TiO2 in liquid form or incorporated into a polymer matrix. CLP labelling is required on packaging.
Are TiO2 pigments subject to anti-dumping duties?
The European Union has imposed anti-dumping measures on titanium dioxide imported from China. Current anti-dumping duty rates should be verified in the TARIC database, as they may vary by producer and review period. These measures do not apply to imports from other countries.
What is the difference between rutile and anatase TiO2?
Rutile has higher density, better hiding power, and greater UV light stability, making it dominant in paints and coatings. Anatase is softer, has a slightly bluish white tone, and is preferred in paper and synthetic fibres. Both types are classified under the same CN code.
What VOC limits apply to paints and coatings CN 3206 11?
Paints and coatings under CN code 3206 11 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
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