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38089400
MISCELLANEOUS CHEMICAL PRODUCTSInsecticides, rodenticides, fungicides, herbicides, anti-sprouting products and plant-growth regulators, disinfectants and similar products, put up in forms or packings for retail sale or as preparations or articles (for example, sulphur-treated bands, wicks and candles, and fly-papers)

Disinfectants

Description and classification

CN code 380894 covers disinfectants put up in forms or packings for retail sale or as preparations or articles. Disinfectants are used to destroy pathogenic microorganisms on surfaces, in water, in air conditioning systems, and in medical applications. Products may be based on chlorine, hydrogen peroxide, quaternary ammonium compounds, alcohols, or aldehydes. Classification requires the product to be a commercial preparation intended for disinfection rather than a pure active substance.

Biocidal and REACH regulations

Disinfectants imported into the EU are subject to the Biocidal Products Regulation (EU) No 528/2012 as product type 1 (human hygiene), type 2 (private and public area), type 3 (veterinary hygiene), or type 4 (food and feed area). The active substance must be approved or under review programme evaluation. REACH requires registration of active substances. CLP requires correct labelling. SDS must be available in the official language of the destination country.

Import and customs procedures

The customs declaration under CN code 380894 must include trade name, active substance, concentration, biocidal product type, and intended use. Customs authorities may require proof of biocidal authorisation or confirmation that the active substance is in the review programme. Disinfectants for medical applications may be subject to additional requirements as medical devices. Duty rates are checked in TARIC.

Disinfectants – biocidal regulations and EU import

Disinfectants under CN 3808 94 include bactericidal, virucidal and fungicidal preparations for healthcare, food industry and surface disinfection. They fall under the Biocidal Products Regulation (BPR) 528/2012 as Product Types 1-5. Import requires active substance registration with ECHA, national authorisation and certificates of analysis. Quality and composition controls for imported disinfectants remain stringent across EU member states.

Frequently asked questions

Does importing disinfectants require biocidal authorisation?
Yes. Disinfectants are biocidal products and require authorisation under Regulation (EU) No 528/2012 or must contain active substances covered by the review programme with valid transitional authorisation under national law.
What biocidal product types cover disinfectants?
Disinfectants cover product types PT1 to PT5 of the biocides regulation: PT1 human hygiene, PT2 private and public area, PT3 veterinary hygiene, PT4 food and feed contact, PT5 drinking water disinfection. Each type has separate requirements.
Is hand disinfectant a biocidal or medical product?
It depends on the declared purpose. Skin disinfecting products for hygiene purposes are biocides PT1. Products disinfecting for therapeutic purposes, such as surgical disinfection, may be classified as medical devices under Regulation (EU) 2017/745.
What BPR product types apply to disinfectants CN 3808 94?
Disinfectants CN 3808 94 may be classified as BPR Product Type 1 (human hygiene), PT 2 (surfaces), PT 3 (veterinary), PT 4 (food contact) or PT 5 (drinking water). Each product type has specific efficacy and safety requirements.