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ESTERS OF ACYCLIC UNSATURATED MONOCARBOXYLIC ACIDS: CLASSIFICATION UNDER THE UKRAINIAN COMMODITY CODING SYSTEM (UKT ZED)
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ESTERS OF ACYCLIC UNSATURATED MONOCARBOXYLIC ACIDS: CLASSIFICATION UNDER THE UKRAINIAN COMMODITY CODING SYSTEM (UKT ZED)



At the request of Transportlux Ukraine LLC, the State Fuel Company "MASMA" conducted testing of the physicochemical properties of a mixture of esters of acyclic unsaturated monocarboxylic acids. Additionally, an expert review was carried out regarding the regulatory requirements for biodiesel fuel. The objective was to determine the classification of this product under the Ukrainian Classification of Goods for Foreign Economic Activity (UKT ZED) and to assess whether excise tax applies to this type of hydrocarbon feedstock.

These ester mixtures are produced via the transesterification of fats and oils with lower alcohols (typically methanol) in the presence of an acid or alkaline catalyst. They are primarily used as feedstock in the chemical and petrochemical industries.

Fatty Acid Methyl Esters (FAME), used as biodiesel or biodiesel components, must comply with the technical requirements of standards such as DSTU EN 14214, EN 14214, DSTU 6081, and ASTM D 6751. If any single physicochemical parameter fails to meet these standards, the product cannot be used as fuel for diesel engines or combustion units and must undergo further purification or processing.

CLASSIFICATION UNDER UKT ZED

According to the Explanatory Notes to the Ukrainian Classification of Goods for Foreign Economic Activity (approved by Order No. 256 of the State Customs Service of Ukraine, dated July 14, 2020), products may be classified under Section 27 "Mineral Fuels..." or Section 38 "Miscellaneous Chemical Products."

Note 5 to Section 27 (p. 483) defines biodiesel as mono-alkyl esters of fatty acids derived from vegetable, animal, or microbial oils and fats, used as fuel. Heading 2710 includes biodiesel blends containing more than 70% petroleum or petroleum-derived products. If the petroleum content is less than 70%, the product is classified under heading 3826.

Section 38 covers a broad range of chemical products. Note 7 to heading 3826 (p. 1019) similarly defines biodiesel as FAME derived from oils or fats of any origin, suitable for use as fuel.

Page 1077 of the Explanatory Notes to UKT ZED states that biodiesel consists of mono-alkyl esters of long-chain fatty acids, is water-insoluble, and has a high boiling point and viscosity similar to petroleum diesel. It is produced by transesterification of fatty acids with methanol or ethanol in the presence of a catalyst. Typical raw materials include rapeseed, soybean, sunflower, palm, cottonseed oils, animal fats, and used cooking oils.

Although biodiesel itself does not contain petroleum-derived products, it may be blended with petroleum diesel. The key characteristic is its suitability for use in diesel engines or heating systems, as defined by recognized standards.

REGULATORY REQUIREMENTS FOR BIODIESEL

According to the Law of Ukraine "On Standardization," standards can be international, regional, national, or of other types and are considered normative documents that define technical specifications and rules.

For a FAME product to be classified as biodiesel fuel, it must meet the requirements of the following standards:

  • DSTU EN 14214
     

  • EN 14214
     

  • DSTU 6081
     

  • ASTM D 6751
     

If any of the specified parameters fall outside the regulated range, the product cannot be classified as biodiesel and is not suitable for use as fuel without further treatment.

TEST RESULTS

According to Test Protocol No. 259/P-25, Table 1 compares the obtained physicochemical properties of the sample with the standard requirements. The analysis revealed:

  • Flash point (closed cup): 41 °C
     

  • Water content: 1.2%
     

  • Methanol content: 0.5%
     

  • Mechanical impurities: 0.011%
     

These values do not comply with the required standards (DSTU 6081, DSTU EN 14214, EN 14214, ASTM D 6751), making the product unsuitable for use as biodiesel or a diesel blend component. In particular, combustion in an engine cannot occur under these conditions.

Although the esters mainly consist of derivatives of oleic, linoleic, and linolenic acids, they can only be used as chemical feedstock, not as fuel.

CLASSIFICATION UNDER UKT ZED

Considering the test results and regulatory framework, the product is classified under the following code:
2916 15 00 00 – Oleic, linoleic, or linolenic acids; their salts and esters.

This code falls under:
2916 – Unsaturated acyclic and cyclic monocarboxylic acids, their anhydrides, halides, peroxides, peroxyacids, and their derivatives.

CONCLUSIONS

The product — esters of acyclic unsaturated monocarboxylic acids—is classified under UKT ZED code 2916 15 00 00 as esters of oleic, linoleic, or linolenic acids.

Its physicochemical characteristics do not meet the requirements of DSTU 6081, DSTU EN 14214, EN 14214, or ASTM D 6751, making it unsuitable for use as biodiesel or a bio-component of diesel fuel. Consequently, it cannot be classified under code 3826.

To obtain marketable biodiesel, the mixture must undergo further processing to meet the following standards:

  • DSTU 6081:2009 – Technical specifications for fatty acid methyl esters (FAME)
     

  • DSTU EN 14214:2019 (IDT) – Requirements for FAME used in diesel engines
     

  • EN 14214:2012+A2:2019 – European standard for biodiesel
     

  • ASTM D 6751-20 – American standard for biodiesel (B100)

Bohdan KOCHIRKO
Chairman of Technical Committee for Standardization TC-38
“Standardization of Petroleum Refining and Petrochemical Products”

Oleh YAROSHENKO
Chairman of Technical Committee for Standardization TC-198
“Solid Renewable Fuels and Biofuels”

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