39073000
PLASTICS AND ARTICLES THEREOF›Polyacetals, other polyethers and epoxide resins, in primary forms; polycarbonates, alkyd resins, polyallyl esters and other polyesters, in primary forms
Epoxide resins
Product characteristics and classification
CN code 390730 covers epoxide resins in primary forms. Epoxide resins are prepolymers or oligomers containing epoxy (oxirane) groups that, when cured with hardeners (amines, anhydrides, amides), form cross-linked polymers with excellent mechanical, adhesive and chemical properties. The most commonly used epoxide resin is the condensation product of bisphenol A with epichlorohydrin (DGEBA). Epoxide resins come as liquids, solid resins, solutions or aqueous dispersions. They are used in protective coatings, structural adhesives, composites, industrial flooring, electrical insulation and construction materials. For customs classification, uncured epoxide resins are classified under code 390730, while cured products may fall under different headings.
Regulatory requirements and BPA safety
Importing epoxide resins into the EU is subject to REACH. Bisphenol A (BPA) is a Substance of Very High Concern (SVHC) on the REACH candidate list due to endocrine-disrupting properties. Epichlorohydrin is carcinogenic Category 1B. BPA-based epoxide resins are subject to restrictions in food contact applications - Regulation (EU) No 10/2011 sets a specific migration limit for BPA of 0.05 mg/kg (amended by Regulation 2018/213). Epoxide resins may cause skin sensitisation - SDS must address allergenic hazards. Aqueous dispersion resins may contain preservatives subject to biocide regulations.
Trade and customs procedures
When importing epoxide resins under CN code 390730, customs documentation should include a specification with resin type (e.g. DGEBA, novolac, cycloaliphatic), epoxy equivalent weight (EEW), viscosity and commercial form. Duty rates should be verified in the TARIC system. Major epoxide resin producers include Hexion, Huntsman, Dow, Nan Ya Plastics and Kumho P&B. The epoxide resin market exceeds 10 million tonnes annually. Liquid resins are transported in drums or tanks. Uncured epoxide resins are generally not ADR dangerous goods. Preferential duty rates may be available under FTA agreements.
Properties of Epoxide resins and trade applications
Epoxide resins classified under CN code 3907 30 are polymers in primary forms (granules, powder, liquid, block) imported as feedstock for plastics processing. Import requires REACH registration, Safety Data Sheets and technical specifications including molecular weight, density and melt flow index (MFI). Products intended for food contact must comply with Regulation (EU) 10/2011 and be listed on the positive monomer list.
Frequently asked questions
Do BPA-free epoxide resins have the same CN code?
Yes. BPA-free epoxide resins (e.g. based on bisphenol F, novolac, cycloaliphatic) are classified under the same code 390730. The tariff code does not distinguish resins by bisphenol type or BPA absence. Differences concern regulatory requirements - BPA-free resins may have easier access to food contact applications.
What BPA limits apply to food-contact resins?
The specific migration limit for BPA from epoxide resins to food is 0.05 mg/kg under Regulation (EU) 2018/213 amending Regulation (EU) No 10/2011. Additionally, BPA is banned in food contact materials for infants. The resin producer should provide a declaration of compliance.
Do hardeners for epoxide resins share the same CN code?
No. Hardeners (amines, anhydrides, polyamides) for epoxide resins are separate chemical substances classified under appropriate tariff headings in Chapter 29 or 38. Code 390730 covers exclusively epoxide resins (prepolymers with epoxy groups) in primary forms.
What technical specifications are needed for import of CN 3907 30?
Import of CN 3907 30 requires specifications: molecular weight, density, MFI, comonomer composition. SDS and REACH registration above 1 tonne/year are mandatory. For food-contact applications, compliance with Regulation (EU) 10/2011 is required.
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