39121100
PLASTICS AND ARTICLES THEREOF›Cellulose and its chemical derivatives, not elsewhere specified or included, in primary forms
Cellulose acetates - Non-plasticised
Product characteristics and tariff classification
CN code 391211 covers non-plasticised cellulose acetates in primary forms. Cellulose acetate (CA) is an ester of cellulose and acetic acid, produced by acetylation of cellulose from wood pulp or cotton linters. In non-plasticised form, cellulose acetate is presented as powder, flakes or granules with a relatively high melting point and hardness. It is used as a raw material for producing textile fibres, cigarette filters, packaging films, spectacle frames and filtration membranes. Classification under CN 391211 requires the product to be a cellulose acetate without plasticisers such as phthalates or citrates. Plasticised cellulose acetates are classified under CN 391212.
REACH requirements and food contact regulations
Cellulose acetates imported into the EU are subject to REACH Regulation (EC) No 1907/2006. As a modified natural polymer, cellulose acetate is exempt from REACH registration, but acetic acid and other substances used in the acetylation process may be subject to registration. Cellulose acetates intended for food contact, for example in packaging films, must comply with Regulation (EU) No 10/2011 on plastic materials intended for food contact, including overall and specific migration limits. Cellulose acetate as a cigarette filter base is subject to the Tobacco Products Directive 2014/40/EU. The Safety Data Sheet should address residual acetic acid content and any solvents present.
Import practice and trade considerations
Customs declarations for cellulose acetates under CN 391211 should specify the degree of acetylation, physical form (powder, flakes, granulate) and confirmation of the absence of plasticisers. Major exporters of cellulose acetates to the EU include the United States, China, Japan and Mexico. Transport of cellulose acetates in dry form is generally not subject to ADR regulations. Preferential duty rates may be available under FTA or GSP schemes, provided origin of goods is documented. Classification requires precise distinction between non-plasticised and plasticised cellulose acetates, as they fall under different tariff subheadings. Binding Tariff Information ruling is recommended where doubts exist.
Properties of Non-plasticised cellulose acetates and trade applications
Non-plasticised cellulose acetates classified under CN code 3912 11 are polymers in primary forms (granules, powder, liquid, block) imported as feedstock for plastics processing. Import requires REACH registration, Safety Data Sheets and technical specifications including molecular weight, density and melt flow index (MFI). Products intended for food contact must comply with Regulation (EU) 10/2011 and be listed on the positive monomer list.
Frequently asked questions
What distinguishes non-plasticised (391211) from plasticised (391212) cellulose acetate?
Non-plasticised cellulose acetate (391211) contains no plasticising additives and has higher hardness and melting point. Plasticised cellulose acetate (391212) contains plasticisers such as phthalates or citrates that lower the processing temperature and increase flexibility. Classification depends solely on the presence of plasticisers in the product.
Does cellulose acetate for cigarette filters require additional import permits?
Import of cellulose acetate in primary form does not require additional permits. However, finished cigarette filters made from cellulose acetate are subject to the Tobacco Products Directive 2014/40/EU and may require compliance with national tobacco regulations. Cellulose acetate as a raw material is classified under CN 391211.
Are cellulose acetates subject to the Single-Use Plastics Directive?
The SUP Directive (EU) 2019/904 concerns finished articles, not raw materials in primary forms. However, cigarette filters made from cellulose acetate are on the list of products covered by the SUP Directive. Manufacturers of cellulose acetate products should consider extended producer responsibility (EPR) obligations.
What technical specifications are needed for import of CN 3912 11?
Import of CN 3912 11 requires specifications: molecular weight, density, MFI, comonomer composition. SDS and REACH registration above 1 tonne/year are mandatory. For food-contact applications, compliance with Regulation (EU) 10/2011 is required.
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