EU introduces separate customs codes for PET flakes

The European Union will introduce separate customs codes for polyethylene terephthalate (PET) flakes from 1 January 2027, allowing their international trade to be recorded separately from other PET forms. The change follows industry engagement by PETCORE EUROPE, which has sought more detailed information about material movements affecting the European plastics and recycling supply chain.

Commission Implementing Regulation (EU) 2026/2163, published in the Official Journal of the European Union on 30 October 2026, establishes the revised Combined Nomenclature (CN) that will apply from the beginning of next year. The changes introduce four eight-digit classifications in place of two existing PET codes, distinguishing flakes from other forms of the polymer within two viscosity categories.

The current nomenclature groups PET flakes and other forms, including pellets, under the same classifications. This means customs and statistical records do not separately identify the quantities and values associated with flake movements. The revised structure will allow those goods to be recorded under dedicated codes, providing additional information about trade in material used within the PET supply chain.

The distinction will be introduced within the existing viscosity classifications rather than through an entirely new customs heading. PET with a viscosity number of 78 ml/g or higher is currently classified under CN code 3907 61 00. From 2027, this will be divided into code 3907 61 10 for PET flakes and 3907 61 90 for other forms of PET within the same viscosity category.

The existing code 3907 69 00, covering PET with a viscosity number below 78 ml/g, will be divided in the same way. Code 3907 69 10 will apply to material in the form of flakes, while 3907 69 90 will cover other forms within that viscosity category.

Current 2026 CN code	New 2027 CN code	Description
3907 61 00	3907 61 10	PET flakes, viscosity number of 78 ml/g or higher
3907 61 00	3907 61 90	Other PET forms, viscosity number of 78 ml/g or higher
3907 69 00	3907 69 10	PET flakes, viscosity number below 78 ml/g
3907 69 00	3907 69 90	Other PET forms, viscosity number below 78 ml/g

The viscosity number is a material characteristic used in the classification of PET. The revised nomenclature retains the distinction between the two viscosity categories while adding a further subdivision according to physical form. A shipment of PET flakes will therefore need to be classified using both characteristics, rather than simply assigned to a single code covering all flake material.

Within the European Union, the Combined Nomenclature provides the basis for classifying goods in customs declarations and compiling international trade statistics. It also supports the application of the Common Customs Tariff. The eight-digit codes identify product categories more precisely than the international six-digit Harmonized System, allowing additional distinctions to be made within the EU’s classification framework.

Customs classifications are used by importers, exporters, and their representatives when preparing trade documentation. The relevant code is associated with the goods being moved and can affect the information required for declarations and the treatment applied under relevant customs measures. Statistical authorities also use the classification system to report trade by product category.

The previous arrangement made it difficult to isolate PET flake trade from broader movements of PET in primary forms. Data recorded under codes 3907 61 00 and 3907 69 00 could include goods with different physical characteristics, preventing analysts from establishing the amount attributable specifically to flakes using those classifications alone.

Separating the categories will allow future import and export records to distinguish flake movements from other PET forms. The resulting data can be analysed by declared quantity, value, trading partner, and other available statistical characteristics. The improvement concerns the specificity of the classification rather than an immediate change in the physical movement or availability of the material.

PETCORE EUROPE has pursued the distinction through its engagement with European institutions. The association represents businesses across the PET value chain and has established an Advocacy Working Group to coordinate industry positions on matters affecting the sector, including trade transparency and the regulatory treatment of recycled materials.

Antonello Ciotti, Chairman of PETCORE EUROPE, said: “This achievement reflects our sustained engagement in advocating for greater transparency and recognition of recycled PET materials in European trade statistics.”

The association expects the additional customs information to support assessments of market conditions, trade flows, and competition affecting European recycling businesses. Import and export statistics can provide evidence about changes in material movements, including the countries from which particular goods are sourced and the markets receiving European exports.

The data may also assist businesses examining the availability of PET flakes within international supply chains. Companies purchasing or processing the material can use trade statistics alongside supplier information and market observations to assess how volumes move between countries. The new codes will provide a more specific statistical category, although they will not reveal the contractual arrangements or technical characteristics of every individual shipment.

An important limitation remains: the new classifications do not distinguish recycled PET from virgin PET. The codes identify material according to its physical form and viscosity category, but neither characteristic establishes whether the polymer has been recovered and reprocessed from previously used products.

A customs declaration identifying PET flakes will therefore not, by itself, confirm that the material contains recycled content. That determination may require separate information concerning its production, composition, and supporting documentation. The new classification can establish that a shipment belongs to the relevant PET flake category without verifying its origin within the recycling process.

The codes also do not distinguish material suitable for food-contact applications from PET intended for other uses. Food-contact suitability is governed by separate technical and regulatory requirements, and customs classification cannot substitute for the information needed to demonstrate compliance with those requirements.

These distinctions are particularly relevant when analysing recycled PET, commonly referred to as rPET. Businesses may use different forms of the polymer during sorting, washing, processing, and subsequent manufacturing activities, while the specifications required for different applications can vary. A more detailed customs code can identify one aspect of a product without establishing its complete material history or intended end use.

PETCORE EUROPE is continuing to advocate for a separate customs classification for recycled PET. Such a development would provide an additional distinction beyond physical form, but no new rPET-specific code or implementation date has been confirmed as part of the January 2027 changes.

The revised nomenclature will also require attention from businesses handling PET imports and exports. Commodity codes may be held within enterprise resource planning systems, product records, customs software, and templates used to prepare recurring declarations. Records currently using 3907 61 00 or 3907 69 00 will need to be reviewed against the new subdivisions before the revised classification applies.

Importers and customs representatives will need sufficient product information to establish the correct code. Where a business handles PET in more than one physical form, the description of the material must be accurate enough to distinguish flakes from other products. The relevant viscosity classification must also be established, allowing the correct eight-digit subdivision to be selected.

Incorrect classification can affect the accuracy of declarations and the trade statistics compiled from them. Introducing additional subdivisions increases the detail available in the reporting system, but the resulting information will only be reliable where goods are classified consistently. The change does not remove the existing responsibilities of businesses and customs representatives to identify their products correctly.

Historical comparisons will require similar care. Figures recorded under the current codes combine flakes and other PET forms, whereas the new categories will separate them. Analysts comparing 2027 trade data with previous years must account for that difference instead of treating the newly reported flake volumes as though they were directly available under the earlier nomenclature.

The classification change does not itself introduce a new recycling requirement, certify recycled content, or establish a particular customs duty increase or reduction. Its immediate purpose is to provide more detailed product categories within the EU tariff and statistical framework. Any applicable duty or trade measure must still be assessed under the relevant customs rules for the goods concerned.

The first trade records prepared under the revised codes will begin to provide separate statistical information about PET flakes from January 2027. As those records accumulate, European recyclers, material suppliers, customs specialists, and policymakers will have a more specific basis for examining international flake movements.

PETCORE EUROPE intends to continue working towards more detailed identification of recycled PET within the customs system. The January changes establish a distinction between flakes and other PET forms, while the association’s broader objective of identifying recycled material separately remains unresolved.