Importing plastics from the UK – HS classification, REACH and duty rates [2026]

Importing plastics from the United Kingdom to Poland is one of the largest bilateral trade flows between the two countries — the HS39 sector (plastics and plastic articles) generates close to $400 million per year in UK-PL trade. Manufacturing firms, packaging plants and plastics processors regularly import polymer granules, films, pipes, profiles and moulded articles from the UK. Since Brexit, however, this trade requires familiarity with two key regulatory areas: tariff classification and duty rates (with TCA preferences), and chemical compliance — both EU REACH on the Polish side and UK REACH on the British side. Non-compliance with REACH can result not only in refusal to place goods on the market, but also in legal liability for the importer. This article is a practical guide to all requirements for importing plastics from the UK in 2026.

Related topic: Plastic Packaging Tax — when must a plastic packaging importer register.

HS39 classification — what does this chapter cover?

Chapter 39 of the Harmonized System (HS) covers plastics and articles of plastics. It is one of the most broadly defined tariff chapters, encompassing both raw materials and finished articles.

Key headings in HS39 for imports from the UK:

HS code	Description	Examples
3901	Ethylene polymers (PE)	LDPE, HDPE, LLDPE granules
3902	Propylene polymers (PP)	PP granules, PP copolymers
3903	Styrene polymers (PS)	PS granules, ABS, SAN
3904	Vinyl chloride polymers (PVC)	Plasticised and unplasticised PVC granules
3905	Vinyl acetate polymers	EVA granules
3907	Polyacetals, polycarbonates, polyesters (PET)	PET, PC, PBT granules
3915	Waste and scrap of plastics	Polymer waste
3916–3918	Profiles, tubes and pipes	PVC/PE/PP pipes, aluminium + plastic profiles
3919–3920	Plates, sheets and film	Stretch film, shrink film, PC sheets
3923–3926	Finished articles	Packaging, containers, technical parts

Correct classification of goods is fundamental — an incorrect classification results in the wrong duty rate being applied and potential customs debt.

HS39 duty rates — how much do you pay when importing from the UK?

EU tariff rates on plastics range from 0% to 6.5%, depending on the tariff subheading:

Type of goods	MFN rate	TCA rate (UK origin)
Polymer granules (3901–3914)	3.0–6.5%	0%
Films and sheets (3919–3921)	3.7–6.5%	0%
Pipes and profiles (3916–3918)	3.7–6.5%	0%
Packaging articles (3923)	6.5%	0%
Waste and scrap (3915)	0%	0%

The 0% TCA rate is only available for goods that satisfy the rules of origin. For plastics, the applicable rule is the so-called specific process rule: polymerisation or copolymerisation must take place in the UK. Granules imported into the UK from Asia and merely repacked do not qualify as UK origin.

Rules of origin for granules and plastics

The TCA rules of origin for HS39 are relatively strict:

• Polymer granules (3901–3914): must be manufactured (polymerised) in the UK — mere change of state or blending is not sufficient
• Films and articles (3916–3926): in most cases, manufacture from non-originating materials is permitted (CTH rule — change of tariff heading), meaning a UK manufacturer may use granules from Asia and the film will still qualify as UK origin

Always request a UK Origin Statement from your supplier (for consignments exceeding £6,000 a REX — Registered Exporter — number is required). Without this document you cannot apply the 0% rate.

UK REACH and EU REACH — two separate systems

This is one of the most important aspects of importing plastics from the UK, and one that is frequently overlooked by importers. Since 2021 the UK and the EU have had two separate chemical regulatory systems:

EU REACH (Regulation EC 1907/2006): - administered by ECHA (European Chemicals Agency) - ECHA registrations are mandatory for substances manufactured or imported into the EU in quantities of ≥1 tonne/year - SVHC (Substances of Very High Concern) candidate list for authorisation — updated twice a year - the Polish importer is responsible for compliance with EU REACH

UK REACH (Chemical Regulations 2021): - administered by HSE (Health and Safety Executive) - separate registration database for the UK - UK SVHC list — largely identical to the EU list but may diverge in future

What does this mean for a Polish importer? - Your UK supplier may be fully compliant with UK REACH, but this does not guarantee compliance with EU REACH - As an importer into the EU you are responsible for ensuring that the imported plastics meet EU REACH requirements - You must hold an SDS (Safety Data Sheet) compliant with EU CLP for each chemical substance or mixture contained in the plastics (where applicable)

SVHC substances in plastics — what to check?

The ECHA SVHC list contains substances of very high concern (carcinogenic, mutagenic, reprotoxic, persistent). Some substances used in plastics production or as additives may appear on the SVHC list.

Practical steps for an importer: 1. Obtain from your UK supplier a Declaration of Compliance or a Declaration of non-presence of SVHC (if the concentration of every SVHC substance in the article is below 0.1% by weight) 2. Check the ECHA SVHC list (updated twice a year) 3. For plastics containing SVHC substances above 0.1% — you are required to inform recipients in the supply chain and consumers (Article 33 EU REACH) 4. If you are importing a chemical substance (not an article) in quantities above 1 tonne/year — check your ECHA registration obligations

UK Plastic Packaging Tax — does it affect Polish importers?

Since April 2022 the UK has introduced the UK Plastic Packaging Tax (PPT) — a tax on plastic packaging containing less than 30% recycled material. The rate in 2026 is £219.90 per tonne.

Who is affected by PPT: - Manufacturers and importers of plastic packaging into the UK — if you import plastic packaging from Poland into the UK, you pay PPT - Importers of plastics from the UK to Poland — PPT in principle does not apply to imports from the UK to Poland (the tax is levied on the UK side)

However, if your UK counterpart manufactures packaging and sells it to Poland, the price may include PPT costs incurred on the UK domestic market. It is worth clarifying this in negotiations.

Extended Producer Responsibility (EPR) UK — packaging

The UK EPR Regulation (in force since 2024) places obligations on UK packaging producers and importers to report the quantities of packaging placed on the UK market and to fund its recycling. It applies to UK entities, not Polish importers — but it indirectly affects the prices of packaging from the UK.

Customs clearance documents for plastics from the UK

A complete list of documents required when importing HS39 goods from the UK:

Document	Issued by	Notes
Commercial invoice	UK exporter	HS code, value, description, Incoterms
UK Origin Statement / REX	UK exporter	Required for 0% TCA rate
CMR / consignment note	Carrier
SDS (Safety Data Sheet)	Manufacturer	EU-compatible, if substance/mixture
Certificate of analysis / CoC	UK manufacturer	For granules: grade, MFI, density
Declaration of non-presence of SVHC	UK manufacturer	For articles — if no SVHC >0.1%

How does customs clearance for plastics from the UK work?

The customs clearance process for HS39 imports from the UK to Poland:

1. HS code identification — work with your customs agent to determine the correct 8-digit CN code
2. Document verification — commercial invoice, origin statement, SDS if required
3. Submission of the customs declaration — in the AES/NCTS system (import procedure 40)
4. Calculation of charges — duty (0% with TCA or MFN), VAT at 23% on the CIF value plus duty
5. Possible customs examination — physical or documentary
6. Release of goods — following payment or provision of a guarantee

Indicative clearance time with a complete set of documents: 1–4 hours.