Major Restructuring of Heading 3915 and Practical Impacts Including Collection Infrastructure Equipment
HS 2028, scheduled to take effect on January 1, 2028, comprises 299 sets of amendments compiled by the WCO (World Customs Organization). The amendment themes explicitly include enhanced monitoring for environmental and enforcement purposes, with the most prominent examples being plastic waste (heading 3915), single-use plastics, and equipment related to collection and sorting.wcoomd
This article organizes, from a business perspective, what will change under HS 2028 and how it will impact corporate operations.
1. Why Are HS Codes for Plastic Waste Undergoing Major Changes Now?
The background lies in the Basel Convention’s plastic waste amendments. Adopted in 2019 and effective from January 1, 2021, new categories (A3210, Y48, B3011) came into force. The key point is that the scope of the Prior Informed Consent (PIC) procedure for transboundary movements of plastic waste has been clarified.wcoomd+1
In particular, B3011—which may be exempt from PIC—covers “exclusively one non-halogenated polymer” or “mixtures of PE, PP, and PET (under certain conditions),” subject to requirements such as being almost free from contamination, free from other types of wastes, and destined for environmentally sound recycling.basel+1
Under HS 2028, this framework is being substantially subdivided on the HS code side (3915) to facilitate classification by hazardousness, polymer type, and mixture composition for customs purposes.wcoomd
2. The Core of HS 2028: Heading 3915 Redesigned by “Hazardousness” and “Material Type”
Under HS 2028, heading 39.15 (waste, parings, and scrap of plastics) is essentially being rebuilt. The broad framework consists of three tiers.wcoomd
2-1. 3915.40: Carving Out Hazardous Plastic Waste
Subheading 3915.40 covers only plastic waste that “contains certain hazardous substances and exhibits hazardous characteristics,” as defined by a new subheading note. The note enumerates examples such as heavy metals and organic halogenated compounds, as well as hazardous characteristics including explosiveness, flammability, corrosiveness, acute toxicity, and ecotoxicity.wcoomd
In practice, this is a domain where supporting documentation such as SDS (Safety Data Sheets), analyses, and contamination/additive information will be strongly required for import/export of waste.
2-2. 3915.51–3915.59: Non-Halogenated, Single-Polymer Waste with Low Contamination Classified by Polymer
Under HS 2028, single-material non-halogenated polymer waste (almost free from contamination and other types of wastes) is subdivided by material type. Representative examples are as follows:wcoomd
- 3915.51: Polyethylene-based
- 3915.52: Polypropylene-based
- 3915.53: Styrene-based
- 3915.54: ABS
- 3915.55: PET
- 3915.56: Polycarbonate
- 3915.57: Polyether
- 3915.58: Urea resins, phenolic resins, melamine resins, epoxy resins, alkyd resins
- 3915.59: Other
This reflects the philosophy aligned with Basel Convention entry B3011’s condition of “single polymer and almost free from contamination”.basel
2-3. 3915.61, 3915.62, 3915.69: Clear Separation of Halogenated and Fluorinated Polymers
Waste containing halogenated polymers is organized separately. Items exclusively of PVC (3915.61), manufacturing scrap of certain fluorinated polymers (3915.62), and others are specified, with the remainder classified under 3915.69.wcoomd
2-4. 3915.91: Mixtures of PE, PP, and PET (Under Conditions) as a Standalone Code
Mixtures consisting solely of PE, PP, and PET that are almost free from contamination and other types of wastes are classified under 3915.91. Others fall under 3915.99.basel
A critically important element is the subheading note rule: “Mixed waste of physically separable dissimilar polymers” is explicitly stated as being classifiable only under 3915.40, 3915.69, 3915.91, or 3915.99—not under single-polymer categories.wcoomd
This means that the common field practice of “forcing classification by predominant material even when mixed” will face constraints.
3. Beyond “Waste”: Definition and Code Provisions for Single-Use Plastics
Under HS 2028, a definition of “single-use” is introduced in Chapter 39, and subheading provisions are being developed with monitoring of single-use plastics in mind. The definition encompasses items that are normally discarded or recycled after a single use and are not intended for repeated or long-term use.wcoomd
Specific examples include single-use drinking straws explicitly listed under 3917.24 or 3917.34, with single-use categories also added for packaging containers (3923) and tableware (3924).wcoomd
This means that product manufacturers may face operational requirements to distinguish “single-use or not” by tariff code, making code management for products—in addition to waste (3915)—a subject for review.
4. Recycling-Related Equipment Also Affected: Reverse Vending Machines Clarified in the HS
Reverse vending machines used for deposit collection are also being clarified under HS 2028. The heading text for 84.76 now explicitly includes “reverse vending machines,” and a dedicated subheading 8476.30 is being created. It is stated that machines with sorting, compacting, and storage components attached are also covered.freightamigo
For companies manufacturing or importing/exporting reverse vending machines, and for retail and beverage companies deploying equipment overseas, the standardization of tariff codes provides stability for contracts and customs clearance. However, if previously classified differently, master data revisions will be required at the time of transition.
5. Translating Impacts on Corporate Operations into Field-Level Language
5-1. As HS Codes Become More Granular, Required Evidence Becomes More Granular
Classification under 3915 will no longer pass on “self-declaration of material” alone. Determining whether something is single-polymer, mixed, halogen-containing, or has hazardous additives or contamination will require specifications, analyses, and process information.wcoomd
5-2. Basel-Related Import/Export Operations Become More Directly Linked to Tariff Codes
Under the Basel Convention, even for B3011—which may be exempt from PIC—conditions such as “environmentally sound recycling” and “almost free from contamination” are explicitly stated. The subdivision of tariff codes serves as a practical tool for implementing these conditions in customs operations.basel
While import/export regulations vary by country and are not uniform, at minimum, “changes in tariff codes may change permit requirements or scrutiny points” becomes a coordination topic between legal/environmental departments and customs departments.basel
5-3. Ripple Effects on Contracts and Costs
When tariff codes change, risks of customs holds, additional analysis costs, re-sorting costs, and return shipping cost burdens materialize. Waste and scrap transactions often have low unit prices, and even minor additional costs can disrupt profitability.
6. Preparatory Actions You Can Start Now
The following are responses for plastic waste and recycling-related items, listed in order of practical effectiveness.
6-1. Change the Approach to Product Inventory
- Reclassify transactions currently under 3915 into four categories: single-polymer, mixed, halogen-containing, and suspected hazardous
- Clarify relevant departments (customs, environmental, legal, sales) for permits and notifications by import/export countrywcoomd
6-2. Establish a Minimum Set of Supporting Documentation
- Evidence of polymer type (process, material certification, analysis)
- Rules for managing contamination/mixing (receiving inspection, sampling, storage methods)
- Verification of recycling destination existence and processing content (contracts, processing flow, receipt records)basel
6-3. Redesign Master Data and EDI for the 2028 Transition
- Design item fields to retain both HS 2022 and HS 2028 (switching by effective date)
- For 3915, include fields for material type, halogen presence/absence, mixing permissibility, and hazardous flag
- Conduct inventory of applicable part numbers for equipment systems such as reverse vending machines (8476.30, etc.)freightamigo
Conclusion
Under HS 2028, plastic waste (3915) is being redesigned by “hazardousness,” “polymer type,” and “mixture composition,” with the introduction of single-use plastic definitions and clarification of reverse vending machines.wcoomd+1
This is not merely a matter of more codes being added; it signifies that transaction processing is shifting toward “classification accompanied by evidence.”
Waste and recycling do not end with customs alone. It is prudent to involve environmental, legal, procurement, and field operations, and to begin inventory and documentation design now—without waiting for 2028.
- https://www.wcoomd.org/en/media/newsroom/2025/april/hsc-provisionally-adopts-the-recommendation-for-hs-2028-amendments-at-75th-session.aspx
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- https://www.credlix.com/hsn-code/8476
- https://www.oecd.org/content/dam/oecd/en/publications/reports/2024/04/monitoring-trade-in-plastic-waste-and-scrap_0c401097/013bcfdd-en.pdf