HS Codes for Plastics

What is the EU import duty on plastics?

EU import duty on plastics under Chapter 39 is generally 6.5% for both raw polymers in primary forms (headings 3901–3914) and articles of plastics (headings 3915–3926). Plastic waste and scrap (3915) is duty-free. These are EU Common External Tariff rates applied to imports from third countries — intra-EU trade in plastics is duty-free.

What REACH obligations apply to plastic exporters?

EU REACH (Regulation EC 1907/2006) imposes obligations on manufacturers and importers of chemical substances. For plastic articles: if the article contains Substances of Very High Concern (SVHCs) above 0.1% by weight, suppliers must inform customers and consumers on request. For polymer raw materials above 1 tonne/year, REACH registration with ECHA may be required. Always check the current SVHC Candidate List for restricted substances in your plastic formulations.

What is the Single-Use Plastics Directive and how does it affect exports?

EU Directive 2019/904 (SUP Directive) restricts or bans certain single-use plastic items in the EU from 3 July 2021. Banned items include: plastic cutlery, plates, straws, stirrers, cotton bud sticks, polystyrene food and drink containers and balloons sticks. Restricted (must meet marking, design or producer responsibility requirements): plastic bottles, cups, tobacco filters, packets, wrappers, wet wipes, sanitary items, lightweight plastic carrier bags. If your product falls into a banned category, it cannot be sold in the EU — regardless of HS code or import duty.

How do I classify automotive plastic parts?

Automotive plastic parts can be classified under Chapter 39 or Chapter 87 depending on the part's function and how it was manufactured. Parts that are identifiable as specific motor vehicle parts (Chapter 87.08) are generally classified in Chapter 87 regardless of material. Generic plastic components (fittings, clips, brackets) that could be used in multiple applications may classify in Chapter 39. The key rule is: if the part is specifically designed for a motor vehicle, Chapter 87 usually takes priority. Chapter 87 typically carries 3.7–4.5% EU duty — lower than Chapter 39's 6.5% for many sub-headings.

What is the UK Plastic Packaging Tax?

The UK Plastic Packaging Tax, effective from April 2022, applies a charge of £200 per tonne on plastic packaging manufactured in or imported into the UK that does not contain at least 30% recycled plastic content. This is not a customs duty — it is an environmental tax paid by the UK manufacturer or the importer of the plastic packaging. All plastic packaging imported into the UK (including packaging used for goods) must be assessed for this tax. Exporters into the UK should provide recycled content certificates to their UK importers to minimise this tax liability.

How do I find the correct HS code for a plastic product using official tools?

Use the EU TARIC database (ec.europa.eu/taxation_customs/dds2/taric) and browse Chapter 39. The key distinction is between primary forms (polymer pellets or granules — headings 3901–3914, classified by polymer type) and articles of plastics (finished plastic products — headings 3915–3926, classified by product function). For raw polymers: identify the type (polyethylene = 3901, polypropylene = 3902, PVC = 3904, PET within polyethers = 3907). For plastic articles: identify the application (packaging = 3923, tableware = 3924, other articles = 3926). For automotive plastic parts, always check whether Chapter 87 (motor vehicle parts) takes priority over Chapter 39.

What happens if plastics are declared with the wrong HS code?

For raw polymer imports, misclassifying between polymer types carries the same 6.5% duty rate — financial impact is minimal but statistical misdeclaration is still an infringement. More significant: classifying automotive plastic parts under Chapter 39 (6.5% EU duty) when they belong in Chapter 87 (3.7–4.5% EU duty) causes overpayment. The reverse — classifying Chapter 87 parts as Chapter 39 when Chapter 87 carries higher duty — results in underpayment with post-clearance liability. For USA imports of Chinese plastics, Section 301 applicability depends on the specific HTS sub-heading — correct classification determines whether 25% additional tariff applies.

How does country of origin affect import duty on plastics?

EU MFN rate for most plastics is 6.5% regardless of origin. Countries with EU FTAs achieve lower rates: South Korean plastics under EU-Korea FTA may qualify for reduced rates; Vietnamese plastics under EVFTA similarly. UK-origin plastic products entering the EU qualify for 0% under TCA if Rules of Origin are met. For the USA: Chinese-origin plastics face Section 301 additional tariffs of 25% on many Chapter 39 products, making sourcing from Southeast Asia, Europe or domestically far more competitive. UK-origin plastics entering the EU receive 0% under TCA, giving EU manufacturers a competitive advantage over Chinese plastics in the UK market for qualified products.

Are there anti-dumping duties on plastics from China in the EU?

The EU has maintained anti-dumping duties on specific Chinese plastic products. Notable examples include PET film (heading 3920) and certain polypropylene packaging materials from China. These ADD measures can be significant — often 10–60% or more on top of the standard 6.5% MFN rate. Always check TARIC for current anti-dumping measures (search by specific HS code with China as origin country) before importing Chinese plastic products into the EU. The EU Commission regularly reviews ADD measures — what had no ADD last year may carry ADD today following a concluded investigation. A Binding Tariff Information ruling can also confirm classification before a large order is placed.

How does the EU-UK TCA affect plastics trade?

Under the EU-UK TCA, EU-manufactured plastic products with EU origin qualification enter the UK at 0% import duty — a significant advantage over the 6.5% UK MFN rate that applies to Chinese or other non-TCA origin plastics. For Portuguese plastic exporters, EU origin gives 0% UK duty versus 6.5% for competitors from outside the TCA area. EU-origin plastic packaging entering the UK still triggers the UK Plastic Packaging Tax (£200/tonne if under 30% recycled content) — this tax applies to all plastic packaging regardless of origin, including EU-preferential TCA goods. Recycled content certificates are therefore important for UK-bound plastic packaging from Portugal.

What REACH restrictions specifically affect PVC and plasticised plastics?

PVC plasticised with phthalates is subject to significant REACH restrictions under Annex XVII. Entry 51 restricts four phthalates (DEHP, DBP, BBP, DIBP) to below 0.1% by weight in plasticised materials in toys and childcare articles. This restriction was extended to cover medical devices and food contact packaging for certain phthalates. DINP and DIDP are restricted to below 0.1% in toys and childcare articles in mouth contact. Importers of PVC products must obtain REACH compliance declarations from manufacturers confirming phthalate content is within limits. Non-compliant products containing restricted phthalates above thresholds are seized at EU customs and reported to RAPEX.

What USA Section 301 tariffs apply to Chinese plastics?

Chinese-origin plastics face Section 301 additional tariffs under USTR List 3: Chapter 39 primary forms (polymer raw materials including polyethylene, polypropylene, PVC, PET) were placed on List 3 at 25% additional tariff. Combined with standard HTS MFN rates of 0–3.7%, Chinese polymer raw materials face effective US duty rates up to 28.7%. Plastic articles (headings 3920–3926 finished goods) from China similarly face 25% additional tariff in most sub-headings. Some product-specific exclusions were granted — check the USTR exclusion database. This makes non-Chinese plastics (EU, South Korean, US-domestic, Southeast Asian) significantly more price-competitive in the US market.

What is the difference between 6-digit, 8-digit and 10-digit HS codes for plastics?

The 6-digit HS code (e.g., 3904 for vinyl chloride polymers/PVC) identifies the polymer group internationally. EU CN8 extends to 8 digits (e.g., 3904.10.00 for PVC, not mixed with other substances) for duty assessment. TARIC 10-digit adds EU-specific measures including any anti-dumping duties on specific products. USA HTS 10-digit codes have different sub-categorisations from EU CN — US polymer classification can differ from EU CN classification at the 8-digit level. Always verify the exact 8-digit CN8 code in the EU TARIC database rather than assuming the EU code mirrors the 6-digit HS; also check US HTS separately for USA-bound shipments.

How should plastic products be declared on a commercial invoice?

A plastics commercial invoice should include: HS code (8-digit CN8 for EU declarations), precise product description (polymer type, product form and application — e.g., 'food-grade HDPE injection-moulded containers' or 'automotive polypropylene trim panel'), declared value, net and gross weight, country of origin (manufacturing country), and for articles of plastics the specific application. For REACH compliance: include reference to the Safety Data Sheet (SDS) number and confirmation that SVHC content is below 0.1% by weight (or disclosure if above). For plastic packaging destined for the UK: include recycled content percentage for UK Plastic Packaging Tax assessment.

What is Binding Tariff Information (BTI) for plastic products?

BTI is a legally binding 3-year HS classification ruling from EU customs authorities. For plastics, BTI is particularly valuable when: (1) A plastic article could be classified under Chapter 39 or as a motor vehicle part under Chapter 87 — often worth 2–3% duty difference. (2) A composite article with significant plastic and non-plastic components has contested essential character. (3) A novel polymer with no clear existing heading is being commercially imported for the first time. (4) High-volume commodity plastics where even a 1% duty rate difference represents significant annual cost. Apply through Portugal's AT. A BTI confirming Chapter 87 over Chapter 39 for an automotive part delivers a meaningful duty saving on all future imports of that specific part.