39123900
PLASTICS AND ARTICLES THEREOF›Cellulose and its chemical derivatives, not elsewhere specified or included, in primary forms
Other
Classification scope for cellulose ethers
CN code 391239 covers cellulose ethers other than carboxymethylcellulose (391231), in primary forms. Products classified under this subheading include methylcellulose (MC), hydroxyethylcellulose (HEC), hydroxypropylcellulose (HPC), hydroxypropyl methylcellulose (HPMC, hypromellose), ethylcellulose (EC) and ethyl hydroxyethylcellulose (EHEC). Cellulose ethers are widely used as thickeners, binders, emulsion stabilisers and binding agents in construction, pharmaceuticals, cosmetics and the food industry. HPMC is a key raw material for producing plant-based pharmaceutical capsules. Classification requires the goods to be a cellulose ether in primary form.
REACH requirements and sector-specific applications
Cellulose ethers imported into the EU are subject to REACH regulation. As polymers they are exempt from registration, but substances used in the etherification process may require ECHA registration. HPMC used in pharmaceuticals must comply with European Pharmacopoeia and GMP requirements. Food-grade cellulose ethers, such as methylcellulose (E461), HPMC (E464) and HPC (E463), must meet the specifications of Regulation (EU) No 231/2012. Cellulose ethers used in construction as additives to mortars and plasters are subject to the Construction Products Regulation (EU) No 305/2011. The Safety Data Sheet should address specific hazards related to dust and residual solvent content.
International trade and customs practice
Customs declarations for cellulose ethers under CN 391239 should specify the ether type (MC, HEC, HPMC, EC), viscosity, physical form and intended use. Major exporters of cellulose ethers to the EU include China, the United States, Japan and South Korea. China is the dominant supplier of HPMC to the European market. Transport of cellulose ethers in powder form is generally not subject to ADR regulations. Preferential duty rates may be available under FTA or GSP schemes. Given the product diversity in this subheading, customs authorities may require technical documentation confirming the cellulose ether type and its distinction from CMC (code 391231).
Properties of Other cellulose ethers in primary forms and trade applications
Other cellulose ethers in primary forms classified under CN code 3912 39 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
Is HPMC (hypromellose) for pharmaceutical capsules classified under CN 391239?
Yes. HPMC in powder form constitutes a cellulose ether in primary form and is classified under CN 391239 regardless of pharmaceutical intended use. Finished pharmaceutical capsules made from HPMC are classified in Chapter 39 as articles or in Chapter 30 as pharmaceutical product packaging.
Which cellulose ethers are approved as food additives in the EU?
Approved cellulose ethers in the EU include methylcellulose (E461), ethylcellulose (E462), hydroxypropylcellulose (E463), hydroxypropyl methylcellulose (E464) and ethyl methylcellulose (E465). All must meet the purity specifications of Regulation (EU) No 231/2012 and may be used in accordance with authorised food applications.
Are there anti-dumping duties on cellulose ethers from China?
Current trade defence measures should be checked in the TARIC database, as they may change. The European Commission may impose anti-dumping duties on specific types of cellulose ethers from particular countries. Importers should verify the status of each product before transacting.
What technical specifications are needed for import of CN 3912 39?
Import of CN 3912 39 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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