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29051200
ORGANIC CHEMICALSAlkohole alifatyczne i ich fluorowcowane, sulfonowane, nitrowane lub nitrozowane pochodne

Propan-1-ol (propyl alcohol) and propan-2-ol (isopropyl alcohol)

Classification scope of subheading 2905 12 — propanol and IPA

Subheading 2905 12 of the Combined Nomenclature covers propan-1-ol (n-propyl alcohol, CAS 71-23-8) and propan-2-ol, commonly known as isopropyl alcohol (IPA, isopropanol, CAS 67-63-0). Both alcohols are saturated, monohydric aliphatic alcohols and separately chemically defined organic compounds within the meaning of Note 1 to Chapter 29 CN. IPA is one of the most widely used industrial solvents — it is used in the production of cleaning agents, paints, cosmetics, disinfectants, pharmaceuticals and electronic materials. Propan-1-ol is used as a solvent and precursor in ester synthesis. Classification under subheading 2905 12 applies to both isomers of propanol, while their mixtures with other alcohols or substances may require different classification. Note 1 to Chapter 29 CN states that the positions of this chapter cover only separately chemically defined organic compounds, with certain exceptions for aqueous solutions. Classification follows the GRI of the CN, in particular Rules 1 and 6. In case of doubt, a Binding Tariff Information (BTI) ruling is recommended.

REACH, CLP, SDS and regulatory framework for IPA and propan-1-ol — import obligations

Both propan-2-ol (IPA) and propan-1-ol are substances registered with ECHA under REACH Regulation (EC) No 1907/2006. An importer from outside the EU importing these substances at 1 tonne or more per year must hold the appropriate REACH registration or obtain it from a registered EU manufacturer or an Only Representative (OR). Under CLP Regulation (EC) No 1272/2008, IPA is classified as a flammable liquid Cat. 2 (H225), eye irritant (H319) and may cause drowsiness and dizziness (H336). Propan-1-ol carries analogous hazard classifications, with an additional reproductive toxicant Cat. 1A classification for occupational exposure. A Safety Data Sheet (SDS) compliant with Regulation (EU) 2020/878 is mandatory and must be prepared in the official language of the member state of delivery. IPA used as an active substance in biocidal products (e.g. disinfectants) is additionally regulated by Regulation (EU) No 528/2012 (BPR). Alcohols used as pharmaceutical raw materials are subject to Directive 2001/83/EC. The import of propanols may be subject to excise duty checks — IPA as a denatured alcohol may be exempt from excise duty after effective denaturing in accordance with relevant Commission regulations.

Duty rates and trade measures for subheading 2905 12

MFN (Most Favoured Nation) duty rates for goods under subheading 2905 12 must be verified in the European Commission's TARIC database, as they may change following annual tariff reviews. For propan-2-ol (IPA), autonomous EU tariff suspensions or tariff quotas may apply if the raw material is not available in sufficient quantities on the EU market. Preferential duty rates are available under FTA agreements concluded by the EU, including CETA (Canada), the EU-Japan EPA, the EU-South Korea agreement and the EU-UK TCA, as well as under the GSP for developing countries. Their application requires compliance with rules of origin and presentation of an EUR.1 certificate, invoice declaration or REX statement. The importer should verify in TARIC whether anti-dumping or countervailing measures apply to the specific goods and country of origin. Subheading 2905 12 falls within Section VI of the CN (Chemical industry products), Chapter 29 — organic chemicals. Import is governed by the Union Customs Code (Regulation (EU) No 952/2013). All duty rates and trade measures must be verified in the current TARIC database.

Chemical safety and SDS requirements

Organic substances under CN code 2905 12 (propan-1-ol and propan-2-ol) 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

Are propan-1-ol and propan-2-ol classified under the same CN subheading when imported into the EU?
Yes, both propan-1-ol (n-propyl alcohol) and propan-2-ol (IPA, isopropyl alcohol) are classified under subheading 2905 12 CN as isomers of propanol. Both are subject to the same MFN duty rates and the same REACH and CLP requirements, although they may hold separate REACH registration numbers and have different Safety Data Sheet (SDS) details. IPA has numerous end uses additionally regulated by the Biocidal Products Regulation (BPR) or pharmaceutical legislation. Current duty rates must be verified in the European Commission's TARIC database.
Does importing IPA (isopropyl alcohol) require special customs or excise authorisations?
IPA is not ethyl alcohol and in principle is not subject to excise duty as a beverage alcohol; however, customs authorities may verify its composition and end use. As a flammable liquid Cat. 2 (CLP), transport of IPA is subject to ADR regulations (UN 1219, Class 3). Import requires an EORI number and a customs declaration. REACH registration or confirmation of registration from the supplier is required when importing 1 tonne or more per year. A Safety Data Sheet (SDS) and CLP-compliant package labelling are mandatory. Duty rates must be verified in TARIC.
What documents are required when importing propanol (subheading 2905 12) into the EU?
Importing propan-1-ol or propan-2-ol under subheading 2905 12 requires: a commercial invoice including the substance CAS number, a transport document (CMR, B/L or AWB), the importer's EORI number and a Safety Data Sheet (SDS) compliant with Regulation (EU) 2020/878. For preferential duty rates, an EUR.1 certificate or invoice declaration is required. An ADR transport document (UN number and hazard class) is required for road transport. The REACH registration status of the substance must be checked in the ECHA database. Current requirements must be verified in the European Commission's TARIC database.
How to classify propan-1-ol and propan-2-ol in customs tariff 2905 12?
Classification of propan-1-ol and propan-2-ol under CN code 2905 12 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.