32082000
TANNING OR DYEING EXTRACTS; TANNINS AND THEIR DERIVATIVES; DYES, PIGMENTS AND OTHER COLOURING MATTER; PAINTS AND VARNISHES; PUTTY AND OTHER MASTICS; INKS›Paints and varnishes (including enamels and lacquers) based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a non-aqueous medium; solutions as defined in note 4 to this chapter
Based on acrylic or vinyl polymers
Subcodes (2)
Tariff classification and scope of CN code 320820
CN code 320820 covers paints based on acrylic or vinyl polymers classified under Chapter 32 of the Combined Nomenclature. Classification is based on chemical composition, commercial form, and intended use. Notes to Chapter 32 specify the scope of individual subheadings. Customs clearance requires proper product identification based on technical documentation, analytical certificates, and commercial specifications. Import of such products into the EU requires compliance with tariff and non-tariff requirements under EU regulations. Potential trade policy measures such as anti-dumping duties or tariff quotas that may affect import costs should also be considered.
EU import regulatory requirements
Import of goods under CN code 320820 into the EU is subject to the REACH Regulation (EC No 1907/2006) and CLP Regulation (EC No 1272/2008). The importer must ensure ECHA registration of each substance. A Safety Data Sheet (SDS) compliant with Regulation (EU) 2020/878 is required. Acrylic paints are subject to the VOC Directive (2004/42/EC). Water-based paints generally have lower limits than solvent-based ones. CLP labelling must include hazard pictograms, signal words, H and P statements. Transport is subject to ADR/RID regulations. These substances are not subject to CBAM. Storage must comply with environmental and occupational health and safety requirements.
Trade aspects and customs documentation
Customs declarations for imports under CN code 320820 should include full specification, CAS numbers, commercial form, and intended use. Importers may benefit from tariff preferences under EU trade agreements or the GSP system. Rate verification in the TARIC database is recommended before each transaction. Export may require verification under the Dual-Use Export Control Regulation (EU) 2021/821. Quality control should include chemical composition testing, specification compliance, and safety requirements verification.
VOC standards and emission limits
When importing Paints based on acrylic or vinyl polymers (CN 3208 20) 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
What are the main applications of products under CN code 320820?
Paints based on acrylic or vinyl polymers are used primarily in the construction, interior decoration, and automotive industries. Specific use depends on the composition and commercial form. Tariff classification is not dependent on end use but on objective product characteristics at the time of customs clearance.
Does import of these products require special permits?
Generally, import does not require separate import permits beyond standard REACH and CLP obligations. For SVHC substances or those subject to REACH authorisation, additional permits may be required. Substance status should be verified in the ECHA database.
How to verify correct classification under code 320820?
Classification can be confirmed by obtaining a Binding Tariff Information (BTI) from the customs authority. A BTI is valid for 3 years and binds customs authorities in all EU Member States. Consulting a customs agency or tariff advisor is also recommended.
What VOC limits apply to paints and coatings CN 3208 20?
Paints and coatings under CN code 3208 20 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.
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