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EU sanctions

CN code 3912 39 and EU sanctions

Cellulose ethers, in primary forms (excl. carboxymethylcellulose and its salts)

Export ban: Belarus, Russia

4 entries in the annexes

Yes. The goods Cellulose ethers, in primary forms (excl. carboxymethylcellulose and its salts) (CN code 3912 39) are subject to EU sanctions in the following regime(s): EU sanctions against Belarus, EU sanctions against Russia. Below: the legal basis (annex and article), direction of the ban, possible exemptions and the regulation version date. A missing code does not mean trade is allowed.

Source version date:

  • Export banEU sanctions against Belarus, Annex Va, Art. 1f(1)
    Annex
    Va
    Article
    1f(1)
    Direction
    export to the sanctioned country
    Source version
    Possible exemption: Cellulose ethers, in primary forms (excl. carboxymethylcellulose and its salts)
    Exemptions and derogations, Art. 1f(1): Derogations from Article 1f are set out in the act text; the Polish wording is quoted in the PL version of this entry. Quoted from consolidated text 02006R0765-20260424. Full conditions and the authorisation procedure are in the article itself. Open the act text on EUR-LexDescription based on the version of 24/04/2026
    Basis: Council Regulation (EC) No 765/2006
  • Export banEU sanctions against Russia, Annex VII, Art. 2a
    Annex
    VII
    Article
    2a
    Direction
    export to the sanctioned country
    Source version
    Exemptions and derogations, Art. 2a: Export ban (dual-use and advanced technology, Annex VII). A Member State competent authority may authorise where the item is necessary for medical/pharmaceutical or humanitarian purposes. Separate derogations: civil telecommunications and cybersecurity (non-public, non-military networks), software updates, interoperability, personal use. Execution of pre-existing contracts may be allowed until cut-off dates that change with packages — check current Art. 2a. Open the act text on EUR-LexDescription based on the version of 24/04/2026
    Basis: Council Regulation (EU) No 833/2014
  • Export banEU sanctions against Belarus, Annex XVIII, Art. 1bb
    Annex entry
    3912
    Annex
    XVIII
    Article
    1bb
    Direction
    export to the sanctioned country
    Source version
    Exemptions and derogations, Art. 1bb: Derogations for Art. 1bb: check the current text of the act on EUR-Lex. We do not yet have a verified description for this article. Open the act text on EUR-Lex
    Basis: Council Regulation (EC) No 765/2006
  • Export banEU sanctions against Russia, Annex XXIII, Art. 3k(1)
    Annex entry
    3912
    Annex
    XXIII
    Article
    3k(1)
    Direction
    export to the sanctioned country
    Source version
    Exemptions and derogations, Art. 3k(1): Export ban on goods enhancing Russian industry (Annex XXIII/XXXVII). A competent authority may authorise where the good is necessary for medical, pharmaceutical or humanitarian purposes. Execution of pre-existing contracts may be allowed until cut-off dates (differing per tranche/addition, e.g. Annex XXIIIE). Further exemptions for EU subsidiaries and divestment. Contract cut-off dates change with packages — check current Art. 3k. Open the act text on EUR-LexDescription based on the version of 24/04/2026
    Basis: Council Regulation (EU) No 833/2014

Can I still ship?

What the act says about exceptions to the ban: the wind-down period for contracts concluded before the ban, the derogations in the article and who grants the authorisation.

Show: derogations in the article, who grants the authorisation

Derogations in the article

We do not have the verbatim wording of the derogations in Art. 1f (Belarus), Art. 2a (Russia), Art. 1bb (Belarus), Art. 3k (Russia) in our database. Read these articles in the act before you conclude that a derogation applies to your shipment.

Open Art. 1f on EUR-LexOpen Art. 2a on EUR-LexOpen Art. 1bb on EUR-LexOpen Art. 3k on EUR-Lex

Who grants the authorisation

Regulation 765/2006 lists in Annex II the websites with information on the competent authorities of the Member States. For Poland: gov.pl/web/diplomacy/international-sanctions.

Regulation 833/2014 lists in Annex I the websites with information on the competent authorities of the Member States. For Poland: gov.pl/web/diplomacy/international-sanctions.

A customs agent will check your contract, the conditions of the derogation and what to prepare for the application.

Ask the customs agent

This is information with its legal basis, not legal advice. We do not confirm that a particular shipment may go ahead. The binding source is the regulation and the decision of the competent authority.

Document this check

A dated report for the shipment file: what was checked, against which version of the law and with what result.

In the document: document number, date and time of the check · scope and result for each regime · legal basis and sources with the act version · what the check does not cover

See the full sample document · The report does not confirm that a transaction is lawful.

Belarus (765/2006)Russia (833/2014)Annex VaAnnex VIIAnnex XVIIIAnnex XXIII

Change alerts in the Pro plan

With the Pro plan you can watch code 3912 39 and as many others as you need. We check EU sources daily and email you when a change affects your code.

Frequently asked questions

Is CN code 3912 39 subject to EU sanctions?

Yes. The goods Cellulose ethers, in primary forms (excl. carboxymethylcellulose and its salts) (CN code 3912 39) are subject to EU sanctions in the following regime(s): EU sanctions against Belarus, EU sanctions against Russia. Below: the legal basis (annex and article), direction of the ban, possible exemptions and the regulation version date. A missing code does not mean trade is allowed.

What is the legal basis and the direction of the ban?

CN code 3912 39 appears in the EU sanctions against Belarus, EU sanctions against Russia regime (annex Va, Art. 1f(1)). Restriction type: Export ban, direction: export to the sanctioned country. Source version date: 24/07/2026. Confirm the full scope on EUR-Lex.

Are there any exemptions or derogations?

Cellulose ethers, in primary forms (excl. carboxymethylcellulose and its salts) Derogations from Article 1f are set out in the act text; the Polish wording is quoted in the PL version of this entry. Quoted from consolidated text 02006R0765-20260424. Full conditions and the authorisation procedure are in the article itself.

How do I document due diligence?

Record the CN code, regime, annex and article, plus the source version date your decision relies on. You can download a PDF report from this page as proof of the check. Note that sanctioned persons and entities are screened separately, against the EU sanctions list.

Related CN codes

3901 3902 3903 3904 3905 3906

All restricted codes in chapter 39 →

This page is informational and is not legal or customs advice. The binding source is the EU regulation and the decision of customs authorities. Screen the persons and entities list separately and check the source version date.