29054900
ORGANIC CHEMICALS›Alkohole alifatyczne i ich fluorowcowane, sulfonowane, nitrowane lub nitrozowane pochodne
Other
Classification scope of subheading 2905 49 — other polyhydric alcohols
Subheading 2905 49 of the Combined Nomenclature is the residual category for polyhydric alcohols (polyols) within Chapter 29, covering those not expressly named in subheadings 2905 31 through 2905 44. The most commercially significant substances within this subheading include pentaerythritol (CAS 115-77-5), xylitol (CAS 87-99-0) and mannitol (D-mannitol, CAS 69-65-8). Pentaerythritol is a tetrahydric aliphatic alcohol (tetrol) — a key raw material for alkyd resins, fatty acid esters, pentaerythritol triacrylate (PETA) used in UV-curable coatings, and a precursor to the explosive PETN (pentaerythritol tetranitrate), which entails specific regulatory controls. Xylitol is a five-carbon sugar alcohol (pentitol) occurring naturally in fruits and plants, used as a food sweetener (E967) and anti-cariogenic agent in dental care products. Mannitol (D-mannitol) is a six-carbon hexitol and stereoisomer of sorbitol, widely used as a pharmaceutical excipient (tablet diluent), osmotic diuretic agent and food sweetener (E421). Classification under subheading 2905 49 requires the substance to be a chemically pure, separately defined organic compound (Note 1 to Chapter 29 CN). Classification follows the GRI, Rules 1 and 6. In case of doubt, a BTI ruling is strongly recommended.
REACH, CLP, SDS and sector regulations for subheading 2905 49 — import obligations
All substances classified under subheading 2905 49 and imported into the EU are subject to REACH Regulation (EC) No 1907/2006. An importer from outside the EU placing pentaerythritol, xylitol, mannitol or other polyols on the EU market at 1 tonne or more per year must hold a REACH registration with ECHA or appoint an Only Representative (OR). Pentaerythritol used in industrial applications may be subject to export controls due to its role as a precursor of PETN (an explosive substance) — importers and exporters should verify obligations under Regulation (EU) No 2021/821 (dual-use export controls) and Regulation (EU) 2019/1148 on explosive precursors. Xylitol and mannitol used as food additives (E967, E421) are subject to Regulation (EC) No 1333/2008 and the purity specifications in Regulation (EU) No 231/2012. Mannitol as a pharmaceutical excipient falls under the European Pharmacopoeia (PhEur) and Directive 2001/83/EC. CLP Regulation (EC) No 1272/2008 requires classification assessment for each substance. An SDS compliant with Regulation (EU) 2020/878 is required. Transport must comply with ADR, IMDG or IATA regulations depending on the CLP hazard classification of the substance concerned.
Duty rates and trade measures for subheading 2905 49
MFN duty rates for goods under subheading 2905 49 must be verified in the European Commission's TARIC database, as they are subject to annual tariff reviews. Pentaerythritol is produced on a large scale in Europe and imported from China, the USA and other countries — the importer should check in TARIC whether anti-dumping duties apply to pentaerythritol from a specific country of origin. Autonomous tariff suspensions may be available for substances not produced in sufficient quantity or 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. The conditions include compliance with rules of origin and submission of EUR.1 certificates, invoice declarations or REX statements. The importer should verify in TARIC all safeguard measures, tariff quotas and tariff suspensions applicable to the specific CN code and country of origin. Subheading 2905 49 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 duty rates and trade measures must be verified in the TARIC database.
Chemical safety and SDS requirements
Organic substances under CN code 2905 49 (other polyhydric 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
Is the import of pentaerythritol subject to explosive precursor controls in the EU?
Pentaerythritol (CAS 115-77-5) is a precursor of PETN (pentaerythritol tetranitrate, an explosive) and may be subject to the provisions of Regulation (EU) 2019/1148 on the marketing and use of explosive precursors. Operators should verify whether pentaerythritol in their specific use context falls under registration requirements or mandatory reporting of suspicious transactions. The export of pentaerythritol to certain destinations may require verification under Regulation (EU) No 2021/821 on dual-use export controls. Independently of precursor controls, the importer must fulfil REACH registration requirements and hold a current SDS. Duty rates should be verified in the TARIC system.
What regulatory requirements apply when importing xylitol as a food substance into the EU?
Xylitol imported as a food additive (E967) must meet the purity specifications set out in Regulation (EU) No 231/2012. The importer should hold a certificate of analysis (CoA) confirming compliance with these specifications. REACH registration, or confirmation from a supplier holding ECHA registration, is required. A Safety Data Sheet (SDS) compliant with Regulation (EU) 2020/878 is mandatory. Xylitol is not classified as a hazardous substance under normal conditions of use (CLP). When used as an anti-cariogenic agent in dental products, it may be subject to Regulation (EC) No 1223/2009 (cosmetics) or relevant medical device standards. Duty rates must be verified in the TARIC system.
How can mannitol (2905 49) and sorbitol (2905 44) be distinguished for customs classification purposes?
Sorbitol (D-glucitol, CAS 50-70-4) and mannitol (D-mannitol, CAS 69-65-8) are stereoisomers — they differ in the configuration of the hydroxyl group at carbon C-2. In the Combined Nomenclature, sorbitol is expressly named in subheading 2905 44, while mannitol is classified in the residual subheading 2905 49 as a remaining polyhydric alcohol. Correct identification requires chemical analysis (spectroscopy, chromatography) and documentation including the CAS number. In case of doubt regarding classification, a Binding Tariff Information (BTI) ruling should be sought. Current duty rates for both substances should be verified in the European Commission's TARIC system.
How to classify other polyhydric alcohols in customs tariff 2905 49?
Classification of other polyhydric alcohols under CN code 2905 49 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.
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