Chemicals CN 280000-293999, 380000-389999: EU duty, REACH and CLP 2026

Quick answer: CN code and import compliance

Conditional answer: there is no single CN code for “chemicals”. Separately defined inorganic elements and compounds are generally tested in Chapter 28, separately defined organic compounds in Chapter 29, and mixtures or preparations not more specifically described in Chapter 38. A use-specific provision for pharmaceuticals, pigments, cosmetics, detergents, adhesives, pesticides or other goods can prevail. Customs release does not establish EU chemical compliance: each substance, including each constituent of a mixture, must be assessed under REACH, CLP and any product-specific regime.

Choosing between Chapters 28, 29 and 38

Classification follows GIR 1, Section and Chapter Notes, and GIR 6. Chapters 28 and 29 narrowly define which impurities, solvents and stabilisers may remain without changing classification. Heading 3824 is residual and cannot override a specific heading. Establish IUPAC name, CAS/EC numbers, structure, UVCB status, purity, impurities, additives, solvents, physical state, manufacturing process, use and packaging. A REACH registration number, UN number or supplier code is not a CN code.

Substance identity and composition file

The importer needs a substance identity profile supported by SDS, certificate of analysis, technical data sheet, quantitative formulation and analytical evidence. For mixtures, assess every constituent and aggregate annual tonnage across imports by the same legal entity. Confidential composition should be transmitted through a lawful mechanism that still allows the EU importer or Only Representative to discharge REACH and CLP duties. Broad concentration ranges are unsafe where a threshold controls classification, registration, restriction or poison-centre notification.

TARIC duty, origin and import VAT

Third-country duty varies by the exact eight-digit CN code and TARIC measures on the acceptance date. Check preferential origin, customs value, anti-dumping/countervailing scope, tariff suspensions, quotas, sanctions and import prohibitions separately. Import VAT is determined in the Member State of importation; standard rates differ, and a chemical does not obtain a reduced rate merely because it is industrial. A chemical reaction may support origin under the applicable rule, while dilution, repacking or relabelling may not.

REACH registration and Only Representative

An EU/EEA importer of a substance on its own or in a mixture generally must register it under REACH before import when its annual quantity reaches one tonne, unless an exemption or an appointed EU Only Representative validly covers that importer and use. Mixtures are not registered as such; constituent substances are. Confirm the registrant, legal entity, tonnage band, substance identity, uses and supply-chain coverage. “No data, no market” remains separate from customs tariff treatment.

CLP classification, label and notification

Before placing a substance or mixture on the market, the importer must classify it under CLP. Hazardous products require compliant packaging and labels, and hazardous substances must normally be notified to the Classification and Labelling Inventory within one month unless the information is already submitted through registration. Harmonised classifications, M-factors, specific concentration limits and ATP updates must be checked. Label language is governed by the Member State in which the product is supplied.

Authorisation, restrictions and special regimes

Screen every CAS/EC number against REACH Annex XIV authorisation, Annex XVII restrictions, the Candidate List, POPs and mercury rules. Prior informed consent under the PIC Regulation can control export/import of listed hazardous chemicals. Biocidal products, plant-protection products, detergents, drug precursors, explosives precursors, fertilisers, ozone-depleting substances and fluorinated gases have additional regimes. A customs code match is only a screening signal; legal scope depends on substance, concentration and use.

SDS, UFI and dangerous-goods transport

A compliant SDS under REACH Annex II must reflect the actual composition and exposure controls. Hazardous mixtures placed on the consumer or professional market may require harmonised poison-centre information and a UFI before supply. Transport is classified separately under ADR/RID/ADN, IMDG or ICAO/IATA using UN number, proper shipping name, class, packing group and environmental hazards. Customs, CAS, EC, UFI, REACH and UN identifiers are not interchangeable.

Customs file and product description

Keep invoice, packing list, transport record, value and origin evidence, formula, SDS, COA, TDS, spectra where needed, REACH registration/OR coverage, CLP assessment, C&L notification, UFI/PCN, authorisation or restriction evidence, product-specific approvals and dangerous-goods documents. Description: “[IUPAC/chemical name], CAS [...], EC [...], ...% purity, ...% solvent/stabiliser, physical form ..., industrial use ..., ... kg drums, CN candidate ..., origin ...”. Avoid “chemical” or a confidential trade name alone.

Official EU sources

Official sources checked 12 September 2026: EU TARIC, ECHA importer guidance, ECHA REACH registration, European Commission REACH and ECHA regulatory support. Recheck TARIC, Candidate List, Annexes and the latest CLP ATP on import.

Limits of this guidance

This is a framework, not BTI, REACH registration or a market authorisation. A final opinion requires every CAS/EC number and exact concentration, identity, structure, purity, impurities, SDS, process, use, annual tonnage per legal entity, packaging, origin, importer and date. An undisclosed constituent may alter CN classification, duty, registration, authorisation, restriction, PCN and transport obligations. The declarant and EU importer retain separate customs and product-compliance responsibilities.