HS code · 6-digit subheading
HS Code 2939.11 – Alkaloids; of opium and their derivatives; salts thereof
HS code 2939.11 is the 6-digit subheading for alkaloids, of opium and their derivatives, salts thereof. It is used for morphine base, codeine base, thebaine base, papaverine base and narcotine base.
What HS 2939.11 covers
This specific HS code covers the raw, unrefined alkaloids derived directly from opium, along with their salts. Opium alkaloids are a class of naturally occurring chemical compounds found in the opium poppy (Papaver somniferum), known for their potent analgesic and sedative properties. This category includes the primary alkaloids like morphine and codeine in their basic forms, before further chemical modification into more complex derivatives. International trade in these substances is extremely tightly controlled due to their high potential for abuse and their classification as controlled substances under international conventions. Major importers and exporters are typically specialized pharmaceutical companies with licenses for handling controlled substances, often for the production of pain medications. Key things to know include the stringent licensing requirements, quota systems, and strict security measures mandated by national and international drug control bodies (e.g., INCB). Trade is highly regulated, often government-to-government or between licensed entities.
- Covers
- Morphine base
- Codeine base
- Thebaine base
- Papaverine base
- Narcotine base
- Morphine sulfate
- Codeine phosphate
- Examples
- Morphine Sulfate API (various licensed manufacturers)
- Codeine Phosphate API (various licensed manufacturers)
- Thebaine (Macfarlan Smith)
- Papaverine HCl (various suppliers)
Codes often confused with 2939.11
Common mistake. This code is specifically for the *raw* opium alkaloids and their salts; it's distinct from their more complex derivatives (293919) or formulated medicaments (Chapter 30).
Top exporters and importers of HS code 293911, 2025
In 2025, the largest exporter of HS code 293911 in UN Comtrade data was Spain, with 23% of world exports; the largest importer in UN Comtrade data was the United States, with 32% of world imports. Countries that did not report 2025 data are estimated from partner records, which can understate them.
Top exporters 2025 · share of world exports
- 1 Spain $67M 23% of world exports
- 2 United Kingdom $66M 23% of world exports
- 3 Czechia $22M 7.6% of world exports
World total: $287M Reported figures on UN Comtrade ↗
Top importers 2025 · share of world imports
- 1 United States $126M 32% of world imports
- 2 United Kingdom $49M 12% of world imports
- 3 Germany $28M 7.1% of world imports
World total: $400M Reported figures on UN Comtrade ↗
How these figures are built
109 countries reported 2025 trade to UN Comtrade in HS 2022, and their own totals are used. Countries that did not report are estimated from what other countries recorded trading with them. Those estimates miss trade with other non-reporting countries, so they can be low, and a non-reporting country can rank higher than shown or be missing from the list. World totals add both and leave out trade between two non-reporting countries. Figures are in current US dollars; reported imports are mostly valued CIF and exports FOB, and exports include re-exports. The UN Comtrade links show the underlying records; they can also list a few reporters left out here (regional groups and older HS editions).
Source: UN Comtrade (United Nations Statistics Division), 2025 annual data.
Brazil NCM codes for 2939.11 18
Brazil splits HS 2939.11 into 18 NCM codes, Mercosur's 8-digit tariff lines.
- 2939.11.10 Concentrates of poppy strawConcentrados de palha de dormideira ou papoula
- 2939.11.2 Buprenorphine, codeine and dihydrocodeine; salts thereofBuprenorfina, codeína e di-hidrocodeína; sais destes produtos Group
- 2939.11.21 Buprenorphine and its saltsBuprenorfina e seus sais
- 2939.11.22 Codeine and its saltsCodeína e seus sais
- 2939.11.23 Dihydrocodeine and its saltsDi-hidrocodeína e seus sais
- 2939.11.3 Ethylmorphine and etorphine; salts thereofEtilmorfina e etorfina; sais destes produtos Group
- 2939.11.31 Ethylmorphine and its saltsEtilmorfina e seus sais
- 2939.11.32 Etorphine and its saltsEtorfina e seus sais
- 2939.11.40 Pholcodine and its saltsFolcodina e seus sais
- 2939.11.5 Heroin, hydrocodone and hydromorphone; salts thereofHeroína, hidrocodona e hidromorfona; sais destes produtos Group
- 2939.11.51 Heroin and its saltsHeroína e seus sais
- 2939.11.52 Hydrocodone and its saltsHidrocodona e seus sais
- 2939.11.53 Hydromorphone and its saltsHidromorfona e seus sais
- 2939.11.6 Morphine and its saltsMorfina e seus sais Group
- 2939.11.61 MorphineMorfina
- 2939.11.62 Morphine hydrochloride and sulphateCloridrato e sulfato de morfina
- 2939.11.69 Other morphine saltsOutros
- 2939.11.70 Nicomorphine and its saltsNicomorfina e seus sais
- 2939.11.8 Oxycodone and oxymorphone; salts thereofOxicodona e oximorfona; sais destes produtos Group
- 2939.11.81 Oxycodone and its saltsOxicodona e seus sais
- 2939.11.82 Oxymorphone and its saltsOximorfona e seus sais
- 2939.11.9 Thebacon and thebaine; salts thereofTebacona e tebaína; sais destes produtos Group
- 2939.11.91 Thebacon and its saltsTebacona e seus sais
- 2939.11.92 Thebaine and its saltsTebaína e seus sais
All Brazil NCM codes in heading 29.39 →
Source: Siscomex NCM table, updated Oct 2026. The Portuguese text is official; the English is our translation.
Questions about HS 2939.11
What is HS code 293911?
HS code 293911 is a 6-digit subheading in the Harmonized System that covers: Alkaloids; of opium and their derivatives; salts thereof. This specific HS code covers the raw, unrefined alkaloids derived directly from opium, along with their salts. Opium alkaloids are a class of naturally occurring chemical compounds found in the opium poppy (Papaver somniferum), known for their potent analgesic and sedative properties. This category includes the primary alkaloids like morphine and codeine in their basic forms, before further chemical modification into more complex derivatives. International trade in these substances is extremely tightly controlled due to their high potential for abuse and their classification as controlled substances under international conventions. Major importers and exporters are typically specialized pharmaceutical companies with licenses for handling controlled substances, often for the production of pain medications. Key things to know include the stringent licensing requirements, quota systems, and strict security measures mandated by national and international drug control bodies (e.g., INCB). Trade is highly regulated, often government-to-government or between licensed entities.
What products fall under HS code 293911?
Morphine base, Codeine base, Thebaine base, Papaverine base, Narcotine base, Morphine sulfate, Codeine phosphate
What are common misclassifications for HS code 293911?
This code is specifically for the *raw* opium alkaloids and their salts; it's distinct from their more complex derivatives (293919) or formulated medicaments (Chapter 30).
Which countries are the top exporters of goods under HS code 293911?
In 2025, the top exporters of HS code 293911 in UN Comtrade data were Spain ($67M, 23% of world exports), the United Kingdom ($66M) and Czechia ($22M). World exports came to about $287M, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Countries that did not report 2025 data are estimated from partner records, which can understate them.
Which countries are the top importers of goods under HS code 293911?
In 2025, the top importers of HS code 293911 in UN Comtrade data were the United States ($126M, 32% of world imports), the United Kingdom ($49M) and Germany ($28M). World imports came to about $400M, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Countries that did not report 2025 data are estimated from partner records, which can understate them.
How is HS code 293911 structured?
HS code 293911 is a 6-digit subheading under the Harmonized System. The first 2 digits (29) identify the chapter, digits 3-4 (39) identify the heading, and digits 5-6 (11) specify the subheading. This code is standardized globally by the World Customs Organization.
What is the Brazil NCM code for HS code 293911?
Brazil splits HS code 293911 into 18 NCM codes: 2939.11.10 (Concentrates of poppy straw), 2939.11.21 (Buprenorphine and its salts), 2939.11.22 (Codeine and its salts), 2939.11.23 (Dihydrocodeine and its salts), 2939.11.31 (Ethylmorphine and its salts), 2939.11.32 (Etorphine and its salts), 2939.11.40 (Pholcodine and its salts), 2939.11.51 (Heroin and its salts), and more listed on this page. The first 6 digits of each match the HS code.