29071900
ORGANIC CHEMICALS›Fenole; fenoloalkohole
Other
Classification scope of subheading 2907 19 — other monohydric phenols
Subheading 2907 19 of the Combined Nomenclature is the residual category for monohydric phenols (monophenols) not expressly named in the preceding specific subheadings. Key substances falling within this subheading include: cresols (ortho-, meta- and para-cresol, CAS 95-48-7, 108-39-4 and 106-44-5) — methylphenols used in the manufacture of disinfectants, synthetic resins (cresylates), pesticides and pharmaceuticals; xylenols (dimethylphenols, e.g. 2,4-xylenol CAS 105-67-9) — used as raw materials for antioxidants, biocides and resins; naphthols (alpha-naphthol and beta-naphthol, CAS 90-15-3 and 135-19-3) — key intermediates in the dye industry, used for the synthesis of azo dyes, leather protection agents and pharmaceuticals; thymol (5-methyl-2-isopropylphenol, CAS 89-83-8) — a natural essential oil constituent from thyme, used as an antiseptic, in aromatherapy and as a food flavouring. Note 1 to Chapter 29 of the CN requires the classified substance to be a separately chemically defined organic compound — commercial mixtures of cresols or xylenols may require classification outside Chapter 29. Classification follows the General Rules for the Interpretation (GRI) of the CN, with Rules 1 and 6 being particularly relevant. In case of doubt, a Binding Tariff Information (BTI) ruling is strongly recommended.
REACH, CLP and SDS for monophenols under subheading 2907 19 — import obligations
All phenolic substances classified under subheading 2907 19 and imported into the European Union are subject to REACH Regulation (EC) No 1907/2006. An importer from outside the EU placing cresols, xylenols, naphthols or thymol on the Union market at 1 tonne or more per year must hold a valid REACH registration with ECHA or appoint an Only Representative (OR) established in the EU. The substances in this subheading exhibit varied and sometimes serious hazard profiles: cresols are classified as toxic (Acute Tox. 3 or 4, H301/H311/H331 depending on the isomer) and corrosive; naphthols, in particular beta-naphthol, may be classified as mutagenic or harmful. The importer must carry out a CLP classification assessment for each substance individually and label packaging accordingly. A Safety Data Sheet (SDS) compliant with Regulation (EU) 2020/878 is mandatory — it must include current toxicological data, workplace exposure limit values (OELs) and transport guidance under ADR/IMDG/IATA. Beta-naphthol (2-naphthol) should be checked against the ECHA SVHC candidate list and Annex XVII to REACH for current restrictions. Thymol used in food or medicinal products is subject to applicable sector-specific regulations including Regulation (EC) No 1334/2008 on flavourings. Each substance under subheading 2907 19 must be assessed individually under REACH, CLP and relevant sector legislation.
Duty rates and trade measures for subheading 2907 19
MFN duty rates for goods under subheading 2907 19 must be verified in the European Commission's TARIC database — individual substances (cresols, xylenols, naphthols, thymol) may carry separate 10-digit TARIC codes with different duty rates and trade measures. The importer must always identify the correct 10-digit TARIC code for the specific substance being imported. Cresols are derived primarily from coal tar and petroleum — global production is dominated by China, South Korea, India and Germany. Naphthols are produced on a large scale in China and India, from where a significant volume is exported to the EU market. The importer should verify in TARIC whether anti-dumping or countervailing measures apply to the specific product from the specific country of origin. 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 19 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 19 (other monophenols) 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 cresols under subheading 2907 19 subject to specific REACH restrictions in the EU?
Cresols (ortho-, meta- and para-cresol) are toxic substances classified under CLP Regulation (EC) No 1272/2008 as acutely toxic by ingestion, skin contact and inhalation, among other hazard categories. The importer must register each cresol isomer separately with ECHA under REACH, or appoint an Only Representative (OR). Para-cresol and other cresol isomers may be listed on the ECHA SVHC candidate list — the current status should be verified with ECHA. An SDS compliant with Regulation (EU) 2020/878 is mandatory. Transport is subject to ADR provisions. Duty rates for subheading 2907 19 should be verified in the European Commission's TARIC system.
Should thymol be classified as a phenol in 2907 19 or as a natural product in a different heading?
Thymol (CAS 89-83-8, 5-methyl-2-isopropylphenol) is a separately chemically defined organic compound with an -OH group directly bonded to the aromatic ring — it is therefore a monohydric phenol and is classified in subheading 2907 19 of the CN, regardless of whether it originates from chemical synthesis or isolation from thyme essential oil. Note 1 to Chapter 29 permits natural substances provided they are chemically pure. Thymol in the form of an undiluted essential oil (a mixture) is classified outside Chapter 29. In case of doubt, a BTI ruling is recommended. Duty rates should be verified in the TARIC system.
What documents are required for importing naphthols under subheading 2907 19 into the EU?
Importing naphthols (alpha-naphthol, beta-naphthol) into the EU requires: a commercial invoice stating the CAS number and purity grade, a transport document (CMR, B/L or AWB), the importer's EORI number, a current SDS compliant with Regulation (EU) 2020/878, and confirmation of REACH registration or appointment of an OR. Beta-naphthol must be checked against ECHA SVHC listings and Annex XVII restrictions to REACH. Packaging must be labelled in accordance with CLP Regulation (EC) No 1272/2008. A proof of origin is required for preferential duty rates. Duty rates should be verified in the TARIC system.
How to classify other monophenols in customs tariff 2907 19?
Classification of other monophenols under CN code 2907 19 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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