Customs classification is one of the quiet deal killers in this trade. The same product can move under several CN headings depending on how it was made, what it is used for and whether the receiving country treats it as a waste or a product, and a reclassification after arrival moves duty, import VAT and energy taxation all at once. We see the same headings come back across our markets, so we have collected them here, product by product, together with the questions that decide between them. Treat the table as orientation: the only binding answers come from your customs authority, ideally in writing through a Binding Tariff Information.
- 1Origin of the material
- 2Chain of custody
- 3Mass balance bookkeeping
- 4Scheme certificate
- 5Claim on the invoice
A claim is only as good as the weakest box to its left.
Commonly used headings, product by product
These are the headings we most often see on the documents crossing our desk. Confirm the individual line and suffix with your customs agent against the current Combined Nomenclature, because lines are amended every year.
| Product | Commonly used CN heading | What decides between the options |
|---|---|---|
| Used cooking oil (UCO) | 3823 80 99 vs 1518 00 99 | National practice differs widely: many member states treat unprocessed UCO as industrial fatty substance, refined UCO as a processed fat under 1518 |
| Animal fats and tallow (category 3) | 1502 | Technical or feed use keeps tallow in 1502; category 1 and 2 material moves under the fatty substance and waste headings instead |
| FAME biodiesel (UCOME, RME, TME, SME) | 3824 99 92 | Mixtures in which petroleum oils make up 70 % or more by weight fall under 2710 19 instead, which is the rule B30 style blendstocks trip over; neat FAME stays in 3824 99 92 |
| HVO and renewable diesel | 2710 19 series | The same family as the fossil gas oil it substitutes; blending composition and sulphur content pick the exact line |
| SAF and aviation kerosene | 2710 19 21 and nearby lines | Blended fuel meeting the jet fuel spec moves under the aviation kerosene line; neat synthetic fractions before blending sit on adjacent lines |
| Bionaphtha | 2710 12 or 2901 | A genuinely live classification question: hydrocarbon naphtha sits under 2710 12, renewable origin naphtha is regularly argued under the hydrocarbon lines of 2901, and practice differs between member states. Worth a BTI before a term flow |
| Pyrolysis oil (TPO and PPO) | 2707, 2710, 2713 or 3824 | Origin and intended use decide: aromatic tyre oils, plastic-derived oils and waste-status oils each land differently, and one UK advance ruling placed heavy plastic-derived oil under 2710 19 71 |
| Glycerine | 1520 00 00 vs 2905 45 00 | Purity: crude glycerine below roughly 95 % glycerol stays under 1520, refined glycerol at or above it moves to the pure glycerol line |
| Crude tall oil, TOFA and pitch | 3803 00 | Tall oil stays in 3803 through considerable refining; that is unusual and worth knowing before a buyer assumes otherwise |
| Waste plastics (bales, regrind) | 3915 series | The polymer decides the suffix; once processed into pellets the cargo leaves 3915 and enters the polymer line, PET for example under 3907 61 |
| Vegetable and technical oils | 1510 to 1518 | The parent oil decides the line; chemically modified and technical grades usually land under 1518 |
Why one product carries several headings
The Combined Nomenclature was written for products, not for waste streams climbing the value chain, so the border question is almost never "what is it" but "what has been done to it and what will it be used for". Three switches do most of the work in our markets.
- Waste or product. The same liquid can be a waste under the shipment rules and a product for customs purposes, or the reverse, and neither answer implies the other. The waste status follows the Waste Shipment Regulation and the member state's end-of-waste practice; the tariff follows the CN text. Settle both separately.
- Processing level. Crude versus refined decides UCO's two realistic headings and glycerine's two, and processing into pellets moves waste plastics out of 3915 entirely.
- Intended use. Blending into mineral fuel pulls a product into the 2710 family even when the chemistry says otherwise, which is precisely the trap with pyrolysis oil destined for refinery upgrading.
The Binding Tariff Information, and when it is worth one
A Binding Tariff Information (BTI) is a written classification issued by one member state's customs authority that binds all EU customs authorities for three years. It costs a modest fee, takes weeks to months, and is applied for through the European BTI e-service. For a one-off parcel it is rarely worth the wait; for a term supply line that will cross the same border monthly, it is the cheapest insurance in the file, because a reclassification after arrival touches duty, import VAT and often excise or energy taxation in one stroke.
Two practical notes from experience. The BTI binds the classification, not the product: change the process or the specification materially and the ruling stops applying. And a ruling obtained in one member state is valid across the EU, but it is still issued under national practice, so argue the file carefully before submitting.
Frequently asked questions
We ship the same product every month. Do we need a new BTI each time?
No, that is the point of one: a Binding Tariff Information is valid for three years across all EU customs authorities, so one ruling covers the whole term flow. What ends the validity is a material change in the product or the process that produced it, so if you change feedstock, process or specification, have the ruling checked before relying on it.
Why does the same product move under different CN codes?
Because classification follows processing level, intended use and waste or product status, not the trade name. Refined UCO is a processed fat, unprocessed UCO is in many member states an industrial fatty substance, and the two carry different headings and different treatment at the border.
Which CN code applies to used cooking oil?
In practice two: 3823 80 99 as an industrial fatty substance and 1518 00 99 as a processed fat or oil. Member states lean differently and practice shifts, so the working answer is: ask the destination authority or cover the flow with a BTI before fixing a term contract.
Which heading does biodiesel move under?
Neat FAME, whatever the feedstock, is commonly classified under 3824 99 92. Blends that contain mineral oil fall under the 2710 19 family instead, which surprises people moving B30 and similar blendstocks.
Is there a dedicated CN code for pyrolysis oil?
No. Depending on origin, aromatic content and intended use, cargoes have moved under 2707, 2710, 2713 and 3824, and one UK advance tariff ruling placed heavy plastic-derived pyrolysis oil under 2710 19 71. Agree the classification with your customs agent in advance; reclassification after arrival moves duty, excise and energy taxation together.
Does an ISCC certificate change the customs classification?
No. Certification says something about sustainability characteristics and chain of custody, not about the tariff. A certified and a non-certified tonne of the same product carry the same heading, and the certificate value lives in the market claim instead.
What is a Binding Tariff Information and is it worth one?
A written, EU-wide binding classification from a customs authority, valid three years. Worth it for any term flow that crosses the same border repeatedly; rarely worth it for a one-off parcel. Apply through the European BTI e-service and argue the file carefully, because the ruling binds the classified product, not your trade name.
Who decides if customs and the importer disagree?
The receiving member state's customs authority decides at the border, which is why national practice matters so much in the UCO headings. A BTI takes that discretion away; a phone opinion does not. The TARIC database shows the current lines and measures but settles nothing.
Can you help us get the paperwork right before a first shipment?
That is part of the brokerage. We check the document pack before it reaches a buyer, including the customs side, and we would rather flag a heading question in week one than lose the margin in a reclassification at discharge. See documentation and safety data sheets.
Market news
Recent headlines from across the feedstock and renewable fuel sector. Nothing specific to this market has come through the wires lately, so this is the wider view. The links go to the publisher; we do not host or edit their reporting, and a headline here is not our endorsement of it. Scroll for more.
- Call for papers on AI for circular economy: Intelligent algorithms for sustainable resource recovery
- NEDO, Kyoto University build world’s first hydrogen beamline at SPring-8-II
- Air Products and Nobian sign long-term agreement for RFNBO-compliant hydrogen
- Romania’s Senate approves green hydrogen law
- Namibia pioneers Africa’s first green hydrogen facility
- Hamburg starts building hydrogen connector for HH-WIN network
- Commercial use of green hydrogen gets under way in Czechia
- Kawasaki Heavy starts Kawasaki hydrogen plant with 18-ton daily capacity
- The Navy, Amyris, Emvolon, Haffner Energy and the Incredible Shrinking Refinery
- ICM supplying processing tech for Atvos’ Brazilian corn ethanol production plant
- Outage at South Africa’s Natref refinery
- Australian Government releases national maritime emissions reduction plan
- Circularity Communicated Conference 2026
- Circular fashion: Design, science and value in a sustainable clothing industry
- nova-Institute hosts the chemical industry defossilisation summit
- Quick Scan Circular Business Models
- Rubbermaid Brilliance line expands with Eastman’s Tritan Renew
- New ABC data reveals how America’s biogas is used today
18 headlines, updated automatically. Last refreshed .
Sources and further reading
Primary sources for the rules and figures on this page, so you can check them yourself. Legislation is amended: always read the consolidated text on the date that matters to you.
Who to ask about CN and HS codes
Just ask. Unsure which heading your cargo moves under? Send us the product, the process and the destination, and we will tell you which headings are realistic and where a binding ruling is worth the money. You get Bart van den Brug on the other end, same working day, in English or Dutch, and across the team also in French, Portuguese, Polish, Czech and Russian.
On how we work: on the feedstocks and fuels on this site we are a broker. We never take title, we do not trade our own book, and we are paid a commission on business that concludes. Additives are the one exception: those we also buy and sell for our own account, and we say in which capacity we are acting before you commit to anything. Either way you will hear it from us when the answer is no, or when your parcel is not ready for the conversation you want to have. A market read or a second opinion on a specification costs nothing and commits you to nothing.
Happy to look at whatever you have, even if it is half an analysis and a question.
+31 6 115 83 448
bart@sustainablecommodities.eu
Sustainable Commodities 3 B.V., Lemmer, the Netherlands
Last reviewed 27 August 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.