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Industry Tariffs Changes Making Impact Plastic & Waste Imports. [HTS 3915]

  • Writer: emails419
    emails419
  • Oct 15
  • 3 min read

Here’s a summary of recent changes and trends affecting HTS 3915 (plastic waste / scrap imports), along with their likely impacts. If you want, I can also provide effects specific to a country (e.g. Mexico, U.S., EU).


Key Changes & Emerging Trends

  1. Stricter Import Controls & Certification Requirements

    • In Malaysia, starting 1 July 2025, import of waste plastic under HS/HTS code 3915 will require a Certificate of Approval (CoA) issued by SIRIM (a government body), rather than the previous Approved Permit mechanism. dagangnet.com

    • The Malaysian regulation mandates that imports only be approved from countries that are parties to the Basel Convention or have a bilateral agreement with Malaysia. Because the U.S. is not a party to the Basel Convention and lacks a bilateral treaty, U.S. exports of plastic waste to Malaysia are disallowed under this rule. Resource-Recycling+1

    • The Malaysian regulation also imposes purity/homogeneity criteria (e.g. mixed loads must be essentially PE, PET, PP only, and non‑resin mixtures must be nearly 99.5% pure) for approval. Resource-Recycling

  2. De facto Bans / Voluntary Trade Restrictions by Carriers

    • Shipping lines such as Maersk have reinforced bans on accepting plastic waste / scrap (HTS 3915) for import into Malaysia. Maersk+1

    • Such carrier policies add an additional layer of constraint beyond official customs regulation.

  3. Changes in Global Waste Trade Patterns (Basel Convention Implementation)

    • The 2021 amendments to the Basel Convention put stricter regulation on cross‑border plastic waste shipments, requiring that exporting and importing countries comply with prior informed consent protocols, and to categorize certain plastic waste streams more strictly.

    • Countries must transpose those Basel obligations into domestic law; Malaysia’s recent rules are an example of that. Resource-Recycling+1

    • As countries adopt stricter controls, flows of plastic scrap are being re-routed, declined, or curtailed, influencing global supply chains.

  4. Increasing Imports in Some Markets, Especially PET Scrap

    • In the U.S., imports of plastic scrap (HTS 3915) have increased, notably PET scrap. In 2024, U.S. plastic scrap imports reached ~492,000 metric tons (a ~10% year‑on‑year increase), with PET accounting for ~51% of the imported volume. Recycling Today+1

    • The “lack of a dedicated HTS code for RPET flake/pellet” has allowed some imported recycled PET to be classified under 3915 (scrap) instead of 3907 (resin), thereby avoiding import duties associated with 3907. Resource-Recycling

    • In Q3 2024, U.S. quarterly plastic scrap imports rose ~11% YoY, with PET making up ~54% of imports. ICIS Explore

    • Some U.S. recyclers are supplementing feedstock with imported PET scrap to meet processing demand, especially when domestic collection is tight. ICIS Explore+2Recycling Today+2

  5. Growing Competition from Cheaper Imported Scrap

    • Domestic recyclers in various markets are concerned that low-cost imported scrap (especially PET) is undercutting local raw material sourcing. Resource-Recycling

    • Because imported material may be cheaper and sometimes of comparable quality, buyers may prefer imports over domestic feedstock. Resource-Recycling

Impacts of These Changes

  1. Reduced Imports into Countries with New Controls

    • Countries implementing stricter certification, bans, or purity thresholds (e.g. Malaysia) will see reduced plastic scrap imports under HTS 3915, especially from exporters that cannot satisfy Basel or certification requirements.

    • For affected exporters, there may be stranded inventory, supply chain interruptions, or rerouting of scrap shipments to other markets.

  2. Higher Compliance Costs & Delays

    • Importers will face increased administrative burden (e.g. applying for CoAs), more documentation, stricter inspections, and possibly rejection at ports if criteria aren’t met.

    • Purity or homogeneity rules mean mixed or contaminated loads become riskier.

    • Carriers’ bans compound delays or refusals of shipments.

  3. Supply Chain Dislocations / Re-routing

    • Exporters previously supplying to now-regulated jurisdictions may shift export destinations (to countries with looser rules) or increase domestic processing.

    • Buyers in restricted markets may turn to alternative feedstock or domestic scrap sources, if available.

  4. Pressure on Domestic Markets via Import Competition

    • In markets where scrap imports are allowed, cheaper imports (especially PET) may displace domestic scrap suppliers and reduce demand for local collection infrastructure.

  5. Regulatory Arbitrage via HTS Classification Ambiguity

    • The blurring of definitions (e.g. recycled PET appearing as “scrap” under 3915 vs resin under 3907) can lead to misclassification to evade duties, which may invite greater scrutiny or customs enforcement. Resource-Recycling

    • Authorities may respond with new codes, audits, or reclassification, raising risk for importers.

  6. Market Uncertainty & Investment Risks

    • Long‑term investments in recycling plants, feedstock sourcing, or trade infrastructure may be delayed or reconsidered due to regulatory unpredictability.

    • Exporters/importers may face stranded contracts if regulations change mid‑stream.


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