Cellulose nitrates (including collodions)

CN code 391220 covers cellulose nitrates (nitrocellulose) in primary forms, including collodion. Nitrocellulose is produced by nitration of cellulose with nitric acid and is classified according to its degree of nitration. Nitrocellulose with a low degree of nitration (below 12.6 percent nitrogen) is used in lacquers, printing inks, adhesives and coatings. Collodion is a solution of nitrocellulose in an ether-ethanol mixture. Highly nitrated nitrocellulose is an explosive and is not classified under CN 391220 but in Chapter 36. Classification under CN 391220 applies only to non-explosive nitrocellulose that is plasticised or wetted for safe transport.

Nitrocellulose is a highly flammable and potentially explosive substance requiring particular attention during import and transport. Transport-grade nitrocellulose must be wetted with water (minimum 25 percent) or alcohol, or plasticised, to prevent self-ignition. Transport is subject to ADR regulations, and the ADR classification depends on the degree of nitration and plasticisation. Nitrocellulose imported into the EU is subject to REACH and to Regulation (EU) 2019/1148 on explosives precursors. The importer must hold a current Safety Data Sheet addressing fire and explosion hazards. Storage requires special fire protection conditions and temperature control.

Customs declarations for cellulose nitrates under CN 391220 should specify the nitrogen content (percent N), type of plasticiser or wetting agent, physical form and intended use. Customs authorities may require documentation confirming that the nitrocellulose is not an explosive and qualifies for Chapter 39 classification. Major exporters of nitrocellulose to the EU include Brazil, China, Thailand and the United States. Given the nature of the goods, correct packaging labelling and ADR transport documentation are of particular importance. Preferential duty rates may be available under FTA agreements. Import of nitrocellulose may be subject to additional controls by public safety authorities.

Cellulose nitrates and collodion classified under CN code 3912 20 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.