Proposed Changes to the Harmonized System of Global Trade

Perc Pineda, PhD
Chief Economist, Plastics Industry Association

Tayce Shamamian
Research Assistant

The past year brought substantial changes to U.S. tariffs and trade policy. This year marks the forthcoming review of the United States-Mexico-Canada Agreement (USMCA). With the international trade landscape in flux, there is another issue, one that has seen less media coverage currently, but will remain a crucial aspect of global trade in the years to come: amending the Harmonized System (HS).

The HS is the standardized tariff classification system that provides the infrastructure for international customs and product identification. This global system categorizes products imported and exported around the world. The HS is the international 6-digit foundation, from which the Harmonized Tariff Schedule (HTS), a country-specific extension of that system, are based on – including extra digits (usually 10 digits) for duty rates and specific import restrictions. The U.S. International Trade Commission maintains the 10-digit HTSUS.

The World Customs Organization (WCO), an independent intergovernmental organization of 187 member countries oversees the global HS for product classification, regularly adopts amendments based on recommendations from participating countries. Last year, members of the WCO agreed on about 300 sets of amendments to the HS. Countries then began their individual processes to incorporate these changes into their own domestic product category systems. The United States and other countries have until January 1, 2028, to implement the changes.

The United States International Trade Commission (USITC) is collecting comments from key stakeholders, which will be submitted to the President and ultimately the WCO. The proposed recommendations that USITC has prepared have major implications for the classification of plastics commodities, particularly regarding plastics products and recyclable plastics materials.

HS changes affecting plastics

The major changes consist of additions of new products and their codes, new categories/headings – such as single-use and rigid products – as well as reclassification of existing codes.

Adding a definition of “single-use” – “goods of a kind normally disposed of or recycled after a single use and that are not for repeated or prolonged use”
HS 3907 Polyacetals, other polyethers and epoxide resins, in primary forms; polycarbonates, alkyd resins, polyallyl esters and other polyesters, in primary forms:
- Addition of “other polyesters” – PBS, PBT, PBAT, and PEF
HS 3913 – Natural polymers (for example, alginic acid) and modified natural polymers (for example, hardened proteins, chemical derivatives of natural rubber), not elsewhere specified or included, in primary forms:
- Addition of PHAs
HS 3915 – Waste, pairings, and scrap of plastics
- Renumbered classification and added HTS for different resin categories – PP, ABS, polycarbonates, polyethers, urea formaldehyde resins
- Expanded category for different compositions of halogenated polymer mixtures
- Added note describing waste under 3915.40 as hazardous if it contains dangerous substances as included in the note, and behaves like a hazardous material
HS 3917 – Tubes, pipes and fittings therefor (for example, joints, elbows, flanges, of plastic)
- Added single use and “other” categories, “rigid” single use and non-rigid “other” are now their own categories, renumbered commodities based on material
HS 3923 – Articles for conveyance or packing of goods, of plastics: stoppers, lid, caps and other closures, of plastics
- Added single use and “other” categories for each product type, and renumbered by material
HS 3924 – Tableware, kitchenware, other household articles and hygienic of toilet articles, of plastics
- Added single use category and “other”, adding new categories based on materials(styrene and PVC), and all materials for “other”
HS 3926 – Other articles of plastics and articles of other materials of headings 3901 to 3914:
- Added single use category to gloves, mittens, and mitts, new product categories for face masks and body bags

Considering that the HS is a globally recognized trade nomenclature, the changes summarized above will have policy implications for global plastics trade beyond trade monitoring.

U.S. plastics trade exposure

Based on 2025 trade flows, the amendments to the HS would lead to changes in classification of about $8.8 billion of U.S. plastics industry exports and $15.5 billion of U.S. plastics industry imports. The current USITC recommendation to the WCO excludes changes to plastics equipment/mold classification. However, businesses in the plastics supply chain that use imported machinery or export machinery outside of the classification of plastics machinery, such as air-conditioning machines which could be reclassified based on the proposal, should be aware of changes that could affect their trading operations – customs declaration/customs clearing.

The proposed changes present an opportunity for the industry to articulate its views – in support for changes that provides positive improvement thereby facilitating trade – as well as providing feedback detailing how the proposed changes are inconsistent with industry practices and need to be improved upon or reconsidered.

PLASTICS has reached out to its membership for feedback to prepare comments to USITC. Industry stakeholders are also encouraged to visit the USITC website to submit comments directly or reach out to PLASTICS to have their perspectives represented.