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29052900
ORGANIC CHEMICALSAlkohole alifatyczne i ich fluorowcowane, sulfonowane, nitrowane lub nitrozowane pochodne

Other

Classification scope and substance characteristics

CN code 290529 covers acyclic unsaturated alcohols not included in subheading 290522 (terpene alcohols), most notably allyl alcohol (prop-2-en-1-ol, CAS 107-18-6) and propargyl alcohol (prop-2-yn-1-ol, CAS 107-19-7). Allyl alcohol is an important organic synthesis intermediate used in the production of glycerol via the epichlorohydrin route, allyl ethers and esters, reactive monomers in resin formulations, and various fine chemical derivatives. Propargyl alcohol is an alkynol widely applied as a corrosion inhibitor in industrial acid pickling processes in the galvanising and oil and gas sectors, as a pharmaceutical intermediate and as a versatile synthetic reagent in the preparation of propargylic derivatives. Classification under CN 290529 pursuant to Note 1 to Chapter 29 requires the substance to be in chemically defined, pure form or as an aqueous solution — technical alcohol blends and products of partial oxidation are generally classified outside Chapter 29. Customs declarations must include the IUPAC name, CAS number, degree of purity and a Certificate of Analysis (COA), as customs authorities may verify the declared purity by requesting laboratory analysis. Chapter 29 encompasses only chemically defined compounds, which excludes technical mixtures or commercial products of variable composition. Misclassification risks customs post-clearance debt and penalties, so it is advisable to seek a Binding Tariff Information (BTI) ruling when classification is uncertain.

REACH, CLP and transport safety requirements

Both allyl alcohol and propargyl alcohol imported into the EU are subject to full REACH obligations (Regulation EC No 1907/2006), including mandatory registration with ECHA in the tonnage band matching the actual annual import volume. Non-EU manufacturers should appoint an Only Representative (OR) in the EU. Allyl alcohol is highly toxic — it is classified under CLP (Regulation EC No 1272/2008) as Acute Tox. 2 (oral and inhalation routes) and Acute Tox. 3 (dermal), resulting in very stringent occupational exposure limit values (OEL) and mandatory use of full personal and collective protective equipment during handling. Propargyl alcohol is classified as Acute Tox. 3 by all routes of exposure and as a flammable liquid. For both substances, a detailed Safety Data Sheet (SDS) prepared in accordance with Regulation (EU) 2020/878 in the official language of the destination country, including full exposure scenarios for all identified uses, is mandatory and must be provided free of charge with every delivery. Transport of allyl alcohol falls under ADR Class 3 with supplementary toxic classification, requiring skull-and-crossbones and flame pictograms and compliance with UN packaging performance standards. Storage requires forced ventilation, anti-static earthing and compliance with ATEX requirements for explosive atmospheres. Spill containment and neutralisation equipment must be available at storage sites.

Customs clearance and practical trade considerations

Importing allyl alcohol and propargyl alcohol under CN 290529 demands meticulous attention to customs documentation given the high acute toxicity of both substances and the resulting obligations under REACH, CLP and ADR. The SAD customs declaration should state the CAS number, degree of purity, net weight, REACH registration number or OR reference, and confirmation that a current SDS is available for the consignee. Allyl alcohol may be subject to national hazardous substance regulations requiring notification or registration with competent authorities in the country of destination. Verify whether an EU Free Trade Agreement with the exporting country or the GSP scheme enables a preferential duty rate — current MFN rates and all available preferences must be checked in the TARIC database before completing the import procedure. Propargyl alcohol supplied as a corrosion inhibitor may require application-specific SDS sections and downstream user communication under Article 31 of REACH, detailing conditions of safe use for the specific application. Export of both substances to high-risk destinations should be screened against dual-use export control obligations under Regulation (EU) 2021/821. Handling requires nitrile gloves, full face protection and adequate forced mechanical ventilation. Storage must meet ATEX requirements and be labelled in accordance with ADR dangerous goods provisions.

Chemical safety and SDS requirements

Organic substances under CN code 2905 29 (Other unsaturated acyclic alcohols) 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

What CLP labelling is required for allyl alcohol imported into the EU?
Allyl alcohol (CAS 107-18-6) requires CLP labelling under Regulation (EC) No 1272/2008 with the skull-and-crossbones and flame pictograms and the signal word Danger. The label must carry the applicable H-statements covering acute toxicity and flammability and the corresponding P-statements in the official language of the destination member state. Due to the very low DNEL and occupational exposure limit values, full collective and personal protective measures are mandatory during unloading and storage operations, including supplied-air or self-contained breathing apparatus when working in enclosed or poorly ventilated areas. A current SDS must be physically available at the workplace.
Is propargyl alcohol subject to specific import restrictions in the EU?
Propargyl alcohol (CAS 107-19-7) is not currently listed in REACH Annex XIV (substances subject to authorisation) or Annex XVII (restricted substances). However, as an Acute Tox. 3 substance by all routes of exposure, it requires mandatory REACH registration with ECHA, a current Safety Data Sheet compliant with Regulation (EU) 2020/878 and full CLP labelling compliance. Export to certain destinations may trigger end-use verification requirements under dual-use export control Regulation (EU) 2021/821. Importers and exporters should regularly verify the current regulatory status of the substance in the ECHA Substance Information database and monitor the SVHC Candidate List for any new entries.
What documents are required to import allyl alcohol into an EU member state?
A commercial invoice including the CAS number, degree of purity, net weight and country of origin, a producer Certificate of Analysis (COA), and a Safety Data Sheet (SDS) in the official language of the destination member state compliant with Regulation (EU) 2020/878 and covering exposure scenarios are all required. Proof of REACH registration or appointment of an Only Representative (OR) established in the EU must be provided. The transport document must correctly state the ADR dangerous goods classification, UN number and packing group. Where preferential duty rates apply under an FTA or GSP, a valid proof of preferential origin such as an EUR.1 movement certificate or REX invoice declaration must be included in the shipping documentation.
How to classify Other unsaturated acyclic alcohols in customs tariff 2905 29?
Classification of Other unsaturated acyclic alcohols under CN code 2905 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.