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29072900
ORGANIC CHEMICALSFenole; fenoloalkohole

Other

Classification scope of subheading 2907 29 — other polyhydric phenols

Subheading 2907 29 of the Combined Nomenclature is the residual category for polyhydric phenols (polyphenols) within Chapter 29, covering those not expressly named in preceding specific subheadings. Key substances within this group include: resorcinol (1,3-dihydroxybenzene, CAS 108-46-3) — used in rubber compounding, adhesive resins, dermatological preparations and as a dye intermediate; phloroglucinol (1,3,5-trihydroxybenzene, CAS 108-73-6) — a pharmaceutical raw material (spasmolytic agent), also used in dye synthesis and photography; pyrogallol (1,2,3-trihydroxybenzene, pyrogallic acid, CAS 87-66-1) — used in analogue photography, hair dye formulations and chemical synthesis; hydroquinone (1,4-dihydroxybenzene, CAS 123-31-9) — used as a polymerisation inhibitor, photographic developing agent and (in restricted applications) a depigmentation cosmetic ingredient. Classification requires the substance to be a separately chemically defined organic compound (Note 1 to Chapter 29 of the CN). Mixtures of polyphenols are classified outside Chapter 29. Classification follows the GRI, Rules 1 and 6. In case of doubt, a BTI ruling is strongly recommended. Importers must always verify the correct 10-digit TARIC code for the specific substance.

REACH, CLP and SDS for polyphenols under subheading 2907 29 — import obligations

Polyphenols classified under subheading 2907 29 and imported into the European Union are subject to REACH Regulation (EC) No 1907/2006. An importer from outside the EU placing any of these substances on the Union market at 1 tonne or more per year must hold a REACH registration with ECHA or appoint an Only Representative (OR). Substances in this subheading present varied and sometimes serious hazard profiles: resorcinol is classified as harmful, skin and eye irritant, and has been identified by ECHA as an endocrine-disrupting substance (ED substance) for the environment, which may trigger future restriction or authorisation procedures under REACH. Hydroquinone is classified as a suspected mutagen (Muta. 2, H341) and carcinogen (Carc. 2, H351) under CLP; its use as a depigmentation ingredient in cosmetics available to consumers is prohibited in the EU under Annex II to Regulation (EC) No 1223/2009. Pyrogallol exhibits acute toxicity and is harmful to aquatic organisms. The importer must perform a CLP classification assessment for each substance individually and label packaging correctly. An SDS compliant with Regulation (EU) 2020/878 is mandatory — it must include current toxicological data, occupational exposure limit values, ecotoxicological data and transport guidance (ADR/IMDG/IATA). Substances from this subheading must be checked against the ECHA SVHC candidate list, Annex XIV (authorisation) and Annex XVII (restrictions) to REACH. Phloroglucinol used as a pharmaceutical starting material is subject to European Pharmacopoeia (PhEur) requirements and GMP provisions.

Duty rates and trade measures for subheading 2907 29

MFN duty rates for goods under subheading 2907 29 must be verified in the European Commission's TARIC database — individual substances may carry separate 10-digit TARIC codes with distinct duty rates and trade measures. The importer must always identify the correct 10-digit TARIC code for the specific substance being imported (e.g. resorcinol, phloroglucinol, pyrogallol or hydroquinone). Resorcinol is produced industrially in Germany, the United States and Japan, with significant volumes also imported from China and South Korea — the importer should check in TARIC whether anti-dumping or countervailing measures apply. Pyrogallol is produced primarily by hydrolysis of gallic acid — major suppliers are located in China, India and Europe. Autonomous tariff suspensions may be available for substances of pharmaceutical or electronic-grade purity not available in sufficient quality on the Union market. Preferential duty rates are available under EU FTAs (CETA, EU-Japan EPA, EU-South Korea FTA, EU-UK TCA) and the GSP for developing countries. Compliance with rules of origin and submission of EUR.1 certificates, invoice declarations or REX statements are required. Subheading 2907 29 falls within Section VI (Products of the chemical industry), Chapter 29 of the CN. The legal basis for import is the Union Customs Code (Regulation (EU) No 952/2013). All current duty rates and trade measures must be verified in the TARIC system.

Chemical safety and SDS requirements

Organic substances under CN code 2907 29 (other polyhydric phenols) require detailed chemical documentation for customs clearance. The Safety Data Sheet must comply with REACH Annex II. Substances classified as hazardous under CLP require GHS pictogram labelling. Transport follows ADR (road) or IMDG (maritime) regulations. Some organic substances may be subject to export controls as dual-use goods. Importers should verify whether the substance requires REACH authorisation (Annex XIV) or is subject to restrictions (Annex XVII).

Frequently asked questions

Is resorcinol from subheading 2907 29 subject to restrictions as an endocrine disruptor in the EU?
Resorcinol (CAS 108-46-3) has been identified by ECHA as a substance with endocrine-disrupting properties for the environment. It is subject to enhanced regulatory scrutiny under REACH and may in the future be subject to authorisation requirements (Annex XIV) or further restrictions (Annex XVII). The importer must hold a current REACH registration with ECHA or appoint an OR, carry out correct CLP classification and labelling, and maintain an up-to-date SDS compliant with Regulation (EU) 2020/878. The current regulatory status of resorcinol on the ECHA SVHC candidate list should be checked regularly. Duty rates should be verified in the TARIC system.
What regulatory requirements apply when importing phloroglucinol as a pharmaceutical starting material?
Phloroglucinol (CAS 108-73-6) used as a pharmaceutical starting material (spasmolytic agent) must meet the identity and purity requirements of the European Pharmacopoeia (PhEur). Its import as a pharmaceutical raw material is subject to GMP (Good Manufacturing Practice) requirements and may require supplier qualification by a notified body or competent medicines authority. REACH registration with ECHA or appointment of an OR is required. An SDS compliant with Regulation (EU) 2020/878 is mandatory. A certificate of analysis (CoA) confirming compliance with PhEur specifications should accompany the shipment. Duty rates should be verified in the European Commission's TARIC system.
Why is hydroquinone strictly regulated in cosmetics despite being classified in Chapter 29 of the CN?
Hydroquinone (1,4-dihydroxybenzene, CAS 123-31-9), while classified as an organic chemical in Chapter 29 of the CN, is prohibited as an ingredient in cosmetic products for consumer use in the EU under Annex II to Regulation (EC) No 1223/2009, due to its CLP classification as a suspected mutagen (Muta. 2, H341) and suspected carcinogen (Carc. 2, H351). Its import as a chemical raw material for industrial uses (e.g. as a polymerisation inhibitor or photographic developer) remains permitted subject to full compliance with REACH and CLP requirements. The importer must hold REACH registration and an SDS compliant with Regulation (EU) 2020/878. Duty rates should be verified in the TARIC system.
How to classify other polyhydric phenols in customs tariff 2907 29?
Classification of other polyhydric phenols under CN code 2907 29 is based on chemical structure and functional groups. If in doubt, you can apply for a Binding Tariff Information (BTI) from the national customs authority.