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39123100
PLASTICS AND ARTICLES THEREOFCellulose and its chemical derivatives, not elsewhere specified or included, in primary forms

Carboxymethylcellulose and its salts

Standard EU duty
0%
VAT
23%
Additional duties / sanctions
0 rules
Docs required
28 docs
Y054Y121Y123Y160Y163Y169+22
Standard rates
Applies toTypeRateConditionsRegulation
ERGA OMNESThird country duty6.5%-R2261/98
Preferences
ERGA OMNES 0%AD 0%AL 0%BA 0%CA 0%CAMER 0%CARI 0%CH 0%CI 0%CL 0%CM 0%CO 0%DZ 0%EBA 0%EC 0%EEA 0%EG 0%EH 0%ESA 0%EUCA 0%FJ 0%FO 0%GB 0%GE 0%GH 0%GSP 0%GSP+ 0%IL 0%JO 0%JP 0%KE 0%KR 0%LB 0%LOMB 0%MA 0%MD 0%ME 0%MK 0%MX 0%NZ 0%PE 0%PG 0%PS 0%SADC EPA 0%SB 0%SG 0%SM 0%SWITZ 0%SY 0%TN 0%TR 0%UA 0%VN 0%WS 0%XC 0%XK 0%XL 0%XS 0%ZA 0%
Notes
CD303The relief from or reduction of customs duties shall be subject to the specific request expressed by the declarant in box 44 "Additional information/Documents produced/Certificates and authorisations", of the Single Administrative Document (SAD)
TM904Preferences granted under the agreement between the European Union and Morocco in force from 19 July 2019.As of 3 October 2025, products originating in Western Sahara subject to controls by the customs authorities of the Kingdom of Morocco shall benefit from trade preferences under the terms of the new Agreement in the form of exchange of letters between the EU and Morocco, The European Union and the Kingdom of Morocco have agreed to allow those products to be identified by reference to the region of origin to be included in the proof of origin and as provided for in Protocol 4.In view of the application of these measures, the origin certificates codes U179 and U180 must be declared.The country code to be entered in the origin declaration when these proofs of origin are used is “EH”.
CD727Eligibility to benefit from this preference is subject to the presentation of an origin declaration stating the European Union origin of the goods, in the context of the Canada-European Union Comprehensive Economic and Trade Agreement (CETA).
CD906The list of non-eligible locations and their postal codes is available at the following address: http://ec.europa.eu/taxation_customs/customs/technical-arrangement_postal-codes.pdf
CD500Eligibility to benefit from this preference is subject to the presentation of a proof of origin stating the community origin of the goods, in the context of the agreement between the European Union and the Swiss Confederation.
5

Binding Tariff Information

BTI classification examples

PLgold5-000841

Carboxymethylcellulose powder for detergents

celluloseGRI 1GRI 6
DEgold341/23-1

Sodium croscarmellose powder for pharmaceutical use

kroskarmeloza sodowa (eter karboksymetylocelulozy)GRI 1GRI 6
ITgold-BTI0499

HPMC powder food additive E464

celluloseGRI 1GRI 6
DEgold441/24-1

Plasticized cellulose acetate in primary form

octan celulozy (plastyfikowany)GRI 1GRI 6
DEgold572/24-1

Microcrystalline cellulose powder

celluloseGRI 1GRI 6

BTI (Binding Tariff Information) is an official EU customs decision confirming the classification of goods. Valid for 3 years, binding across all EU member states.

Product characteristics and tariff classification

CN code 391231 covers carboxymethylcellulose (CMC) and its salts, including sodium carboxymethylcellulose (Na-CMC), in primary forms. CMC is a cellulose ether obtained by reacting alkali cellulose with monochloroacetic acid. In powder or granule form, CMC is water-soluble and produces solutions of controlled viscosity. It is used as a thickener, stabiliser and binder in the food, pharmaceutical, cosmetic, petroleum and paper industries. In the food industry, CMC is registered as additive E466. Classification under CN 391231 requires the goods to be CMC or its salt in primary form, not a ready-made preparation containing CMC as one of several ingredients.

Regulatory requirements and food safety

CMC imported into the EU is subject to REACH regulation. As a cellulose derivative, CMC is exempt from REACH registration as a polymer, but substances used in the production process may be subject to registration. Food-grade CMC (E466) must meet the specifications of Commission Regulation (EU) No 231/2012 laying down specifications for food additives. In 2021, EFSA re-evaluated CMC and confirmed its safety as a food additive, while noting the need for purity monitoring. Pharmaceutical-grade CMC must comply with European Pharmacopoeia requirements. The Safety Data Sheet for industrial CMC should address dust inhalation risk and appropriate protective measures.

Import practice and trade considerations

Customs declarations for CMC under CN 391231 should specify the degree of substitution (DS), solution viscosity, physical form and intended use (food, pharmaceutical, technical). Major exporters of CMC to the EU include China, Finland, the United States and India. Food-grade CMC requires additional documentation confirming compliance with E466 specifications. Transport of CMC in powder form is generally not subject to ADR regulations but requires protection from moisture. Preferential duty rates may be available under FTA or GSP schemes. Importers should check TARIC before completing import transactions.

Properties of Carboxymethylcellulose CMC and trade applications

Carboxymethylcellulose CMC classified under CN code 3912 31 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

Are food-grade (E466) and technical CMC classified under the same code?
Yes. Both food-grade CMC (E466) and technical CMC are classified under CN 391231 provided they are in primary form. The difference lies in quality and regulatory requirements, not tariff classification. Food-grade CMC must comply with the specifications of Regulation (EU) No 231/2012.
What specifications must CMC intended for food use meet?
Food-grade CMC (E466) must meet the purity specifications laid down in Commission Regulation (EU) No 231/2012, covering sodium content, degree of substitution, viscosity and contaminant limits. The manufacturer or importer should hold a certificate of analysis confirming compliance with the specifications.
Does CMC require CLP labelling?
CMC in powder form is generally not classified as a hazardous substance under CLP. However, CMC dust may present an inhalation hazard, which should be addressed in the Safety Data Sheet. CLP labelling is not required if CMC does not meet the hazard classification criteria.
What technical specifications are needed for import of CN 3912 31?
Import of CN 3912 31 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.