Importing paper, board and packaging from the UK – HS48 classification and customs documents

Importing paper, board and packaging from the United Kingdom to Poland is a market worth several hundred million dollars a year — one of the largest HS48 trade flows between the two countries. Polish printing companies, packaging manufacturers, distributors and logistics firms regularly source printing paper, corrugated board, cartons, paper bags and finished packaging from the UK. Since Brexit, this trade requires familiarity with several overlapping regulatory layers: correct HS48 customs classification, TCA rules of origin, new UK packaging regulations (UK EPR 2024), the Plastic Packaging Tax, and — for paper made from wood pulp — the EUDR regulation. This article is a complete guide to all the formal requirements and costs of importing paper and board from the UK in 2026.

HS48 classification — what does this chapter cover?

Chapter 48 of the Harmonized System (HS) covers paper and paperboard; articles of paper pulp, paper or paperboard. It is one of the most varied tariff chapters, covering both raw materials and finished packaging products ready for use.

Key CN codes for imports from the UK:

CN Code	Description	Grammage / Notes
4801 00 00	Newsprint	In rolls or sheets
4802	Uncoated paper and paperboard for printing	Uncoated, various grammages
4803	Toilet tissue, handkerchiefs	Tissue
4804	Uncoated kraft paper and board	Uncoated, sacks, packaging
4808	Corrugated paper and paperboard	Flute A, B, C, E, F
4810	Kaolin-coated paper	LWC, MWC, art paper
4811	Otherwise coated paper	Thermal paper, silicone paper
4816	Self-adhesive paper and board	Labels
4819	Boxes, bags, sacks of paperboard	Finished packaging
4820	Exercise books, notebooks, pads	Stationery articles
4823	Filter paper, tissue paper	Other

Correct classification to the 8-digit CN code is critical — different subheadings carry different duty rates and the choice can be significant for EUDR purposes.

Duty rates on paper and board from the UK

EU tariff rates for HS48 vary by subheading:

Type of goods	CN Code	MFN rate	TCA (UK origin)
Newsprint	4801	0%	0%
Uncoated printing paper	4802	0%	0%
Kraft board (sacks)	4804	0–7%	0%
Corrugated board	4808	0%	0%
Coated paper (LWC, art)	4810	0–7%	0%
Finished packaging (boxes)	4819	0–6.5%	0%
Multi-layer paper sacks	4819	6.5%	0%
Self-adhesive paper	4811	0–6.5%	0%

It is worth noting that newsprint and uncoated printing paper carry an MFN rate of 0% — here the TCA confers no additional benefit. However, for finished packaging and paper bags the MFN rate of up to 6.5% means that UK origin (0% under TCA) delivers a genuine financial saving.

Rules of origin for paper — how do they work?

Rules of origin for HS48 under the TCA are based primarily on the CTH (Change of Tariff Heading) criterion — a change of tariff subheading at the 4-digit level:

A UK manufacturer may use pulp or paper from any country provided the production of the finished product takes place in the UK and changes the CN code at the 4-digit level
Example: pulp imported from Finland (HS47) → production of printing paper in the UK (HS4802) → change of heading → UK origin ✓
Exception: some paper products have stricter rules — e.g. a minimum share of UK-origin pulp may be required

The UK exporter must provide a UK Origin Statement (for consignments ≤ £6,000) or hold REX (Registered Exporter) status for larger shipments. Without an origin document it is not possible to apply the 0% TCA rate.

UK EPR — Extended Producer Responsibility for packaging (2024)

Since 2024 the UK has implemented UK EPR (Extended Producer Responsibility for Packaging) — one of the most far-reaching producer and importer responsibility schemes for packaging in Europe.

What this means in practice: - Producers and importers of packaging for the UK market must register with the UK EPR scheme - Obligation to report the quantities and types of packaging placed on the UK market (annually) - Funding of the UK packaging collection and recycling system (EPR fees — so-called "modulated fees") - UK EPR fees affect the costs of British suppliers and indirectly influence export prices

For the Polish importer: UK EPR does not impose direct obligations on the Polish side, but a UK supplier may include EPR costs in the price of goods. This is worth factoring into price negotiations.

On the Polish side, importers of packaging into Poland are subject to the Polish Act on packaging and packaging waste management — a separate, national scheme.

Plastic Packaging Tax UK — tax on plastic packaging

Since 1 April 2022 the UK has levied a Plastic Packaging Tax (PPT) — a tax on plastic packaging containing less than 30% recycled material. In the 2026/27 tax year the rate is £219.90 per tonne (£210.82 in 2025/26).

Who PPT applies to: - Manufacturers and importers of plastic packaging for the UK market (≥10 tonnes/year registration threshold) - PPT covers plastic packaging for both retail and industrial use

Does PPT apply to imports of paper packaging from the UK to Poland? - Paper packaging with no plastic → PPT does not apply - Multi-material packaging (paper + plastic film) → may apply if the dominant component is plastic

For importers of paper packaging from the UK, PPT typically has no direct application on the Polish side. It may, however, affect market prices for multi-material packaging.

EUDR for paper — does it apply to imports from the UK?

Yes — paper made from wood pulp is covered by the EUDR (EU Deforestation Regulation, Reg. 2023/1115). This covers: - paper and board produced from wood pulp (HS47 → HS48) - it does not cover paper made from recovered fibres (recycled pulp)

How the EUDR works for importers of paper from the UK: 1. The importer must carry out due diligence — establish whether the raw material (timber/pulp) originates from forests not associated with deforestation after 31 December 2020 2. The UK producer should provide supply chain documentation: the origin of the pulp (country, FSC/PEFC certificates) 3. If the pulp originates from EUDR high-risk countries → enhanced due diligence applies 4. The importer submits a due diligence statement in the EU EUDR system

Paper made from recovered fibres (recycled paper, e.g. code 4707, 4802 in the recycled variant) is as a rule not subject to the EUDR, because it does not derive from newly harvested timber. It is advisable to confirm this with the supplier and retain documentation of the recycled content.

How to order paper from the UK without VAT?

A frequently asked question: do I pay UK VAT when buying paper from a UK producer?

The answer is: No — exports from the UK are zero-rated for UK VAT purposes. The UK supplier issues an invoice without UK VAT (0% UK VAT on exports), provided the goods are dispatched outside the UK and the supplier holds proof of export (CMR, EAD from UK customs).

On the Polish side: - Import into Poland → VAT at 23% is levied in Poland by the customs authority on the CIF value of the goods plus duty - As an active VAT taxpayer in Poland you may deduct import VAT on the basis of the customs document (SAD/PZC) - If you use Procedure 42 (Regime 42) → import VAT is suspended when the goods are forwarded to another EU member state

Documents for customs clearance of paper and board from the UK

Full document checklist for HS48 imports from the UK:

Document	Issued by	Notes
Commercial invoice	UK exporter	Grammage, width, format, paper type
UK Origin Statement / REX	UK exporter	Mandatory for 0% TCA rate
EUR.1 certificate or statement of origin	UK exporter	Alternative to UK Origin Statement
CMR / consignment note	Carrier
Technical specification / quality certificate	UK manufacturer	Grammage g/m², brightness, moisture
FSC/PEFC CoC	UK manufacturer	Supporting EUDR (if timber-derived)
EUDR Due Diligence Statement	Polish importer	If paper is made from wood pulp

Key issues when importing packaging from the UK

Outer packaging vs unit packaging

The customs classification of packaging can be non-obvious: - Empty corrugated boxes (4819) → duty up to 6.5% MFN - Printed / personalised boxes → still 4819, but worth checking whether any exclusion applies - Plastic bags and sacks → HS39 (not HS48) → different rates and regulations

Multi-material packaging rules

Board packaging with a plastic window (e.g. food product boxes) is classified according to the dominant material. This is typically board → HS4819.

Packaging labelling requirements for the Polish market

Packaging placed on the market in Poland must comply with Polish and EU labelling requirements — including rules on recyclability icons (triangle with resin code number for plastics), "suitable for recycling" markings, and manufacturer identification.

Step by step — how to import paper from the UK safely

Establish the CN code — 8-digit, e.g. 4810 13 00 (LWC coated paper) or 4819 20 00 (folding boxes of corrugated board)
Verify the supplier — check whether they hold REX status or can issue a UK Origin Statement
Check the EUDR position — is the paper made from wood pulp or from recycled fibres? Gather EUDR documents if required
Arrange transport — ensure the CMR contains a full description of the goods (CN code, weight, description)
Submit for clearance — the customs agent lodges the import declaration with the CN code, CIF value and TCA documents
Pay VAT — or use a suspended procedure (AEO, guarantee)
Account for VAT — deduct import VAT in the VAT return on the basis of the PZC customs document

FAQ

Does importing paper from the UK to Poland require an FSC certificate? FSC is not a mandatory certificate for customs clearance, but it is required as part of EUDR due diligence for paper made from wood pulp. An FSC CoC from the UK supplier helps document the legality of sourcing and simplifies the submission of the EUDR statement.

Is recycled paper subject to the EUDR? As a rule, no — the EUDR covers goods derived from newly harvested timber. Paper made from recovered fibres (recycled raw material) should not require EUDR due diligence. It is nonetheless advisable to obtain confirmation from the UK supplier regarding the recycled content.

What duty rates apply to corrugated board packaging from the UK? Empty board packaging (boxes, paper bags) classified under HS4819 is subject to an MFN rate of up to 6.5%. With TCA and UK origin — the rate is 0%. Printing paper (4802) carries an MFN rate of 0% — here the TCA confers no additional financial benefit.

Is UK VAT added to the invoice when buying paper from the UK? No — exports from the UK are zero-rated (UK VAT rate = 0% for exports). The UK supplier issues an invoice without UK VAT. VAT is charged in Poland as import VAT (23%) at customs clearance.

Does UK Plastic Packaging Tax apply to paper packaging imported into Poland? PPT applies to plastic packaging containing less than 30% recycled content placed on the UK market. Imports of paper packaging from the UK to Poland are not subject to PPT. It may, however, affect prices for multi-material packaging (paper + plastic).

How much does customs clearance of paper and board from the UK cost? Import clearance of paper and board from the UK costs approximately £45 to £120 per customs declaration, depending on the number of tariff lines and the value of the consignment. Negotiated rates are available for high-volume shipments.

easyclearance.pl