A container of polypropylene granules and a container of finished plastic crates can carry the same supplier invoice, cross the same port and land in the same warehouse. Under chemicals law they are different things. Anyone planning to import plastics to the UK needs to know which of the two they are bringing in, because that decides whether UK REACH asks for a registration, a notification, a label of information for customers — or nothing at all.
Import plastics to the UK: substance, mixture or article?
UK REACH, the chemicals regime that applies in Great Britain, regulates substances. According to the Health and Safety Executive (HSE), a registrant must collect information on the properties and uses of the substances they “manufacture or import above one tonne a year”. Registration applies to substances on their own, to substances in mixtures, and “in certain limited cases to substances in articles”.
For plastics this creates three practical categories:
- Polymers as raw material — pellets, granules, powders and resins bought for moulding or extrusion.
- Mixtures — masterbatches, compounds and polymer blends carrying pigments, plasticisers, flame retardants or other additives.
- Articles — finished goods whose shape matters more than their chemistry: crates, pipes, film, housings, toys.
Each sits under a different set of duties, and one shipment can contain more than one category. Classify at SKU level, not at container level.
Polymers are exempt from registration — their monomers may not be
The retained REACH text published on legislation.gov.uk is direct: “The provisions of Titles II and VI shall not apply to polymers.” Title II is registration. An importer of polypropylene or PET resin therefore does not register the polymer itself.
The exemption stops at the polymer. Article 6(3) requires an importer of a polymer to register the monomer substances (or other substances bound into the polymer) where two conditions are both met: the polymer consists of 2% weight by weight or more of such monomer substances in the form of monomeric units and chemically bound substances, and the total quantity of those monomers reaches one tonne or more per year. The duty applies only where the monomers have not already been registered further up the supply chain.
That last condition is the one to check with your supplier. A GB importer buying from an EU producer cannot rely on the producer’s EU REACH registration: EU REACH and UK REACH are separate systems. Non-GB manufacturers can, according to HSE, appoint a “GB-based Only Representative (OR) to take on the registration responsibilities”, which removes the obligation from the importer. Ask in writing whether an OR exists for your product before the first shipment.
Additives and masterbatch: treat them as chemicals
Masterbatches and compounded plastics are mixtures, and the additives in them are substances in their own right. Plasticisers, stabilisers and flame retardants imported above one tonne a year fall into the registration logic described by HSE, exactly as they would if you imported them in a drum. This is where many plastics importers are caught out: the polymer exemption covers the backbone of the material, not the chemistry mixed into it.
If your business imported substances or mixtures from the EU before the end of the transition period, HSE notes that “downstream user import notification provisions may apply to you” — the DUIN route that gov.uk describes for businesses continuing to import EU REACH-registered substances. Whether any transitional deferral still covers your product is a question for HSE’s current guidance, not an assumption to make from an old notification. Check the current UK REACH submission deadlines on the HSE website before relying on them.
Finished plastic articles: the SVHC 0.1% rule
For finished plastic goods, the main risk is not registration but substances of very high concern (SVHCs) on the UK REACH Candidate List. HSE sets out two separate duties.
Notification. Importers of articles must notify HSE where a Candidate List substance is present in their articles in quantities totalling over one tonne per importer per year and above a concentration of 0.1% w/w.
Communication. Independently of tonnage, if you supply an article containing a Candidate List substance above 0.1% w/w, you “must provide the recipient of the article with sufficient information to allow safe use of the article” — as a minimum, the name of the substance. Consumers can request the same information, and HSE states you “must provide this information within 45 days of receipt of the request”.
The practical step is the same for every finished plastic product: ask the supplier for an SVHC declaration per product, checked against the UK REACH Candidate List rather than the EU one.
The customs side: commodity code, origin, packaging
REACH compliance does not replace the import declaration. Plastics and articles thereof are classified in chapter 39 of the UK Global Tariff, and the commodity code determines the duty. For goods coming from the EU, zero duty under the UK-EU Trade and Cooperation Agreement depends on meeting the product-specific rules of origin and holding valid proof of origin — EU dispatch alone is not enough. Our partner’s guide to plastics classification in HS chapter 39 and the two REACH regimes covers the tariff structure from the other direction of the same trade lane.
One further tax sits beside customs. gov.uk requires registration for Plastic Packaging Tax if you “expect to import into the UK or manufacture in the UK 10 tonnes or more of finished plastic packaging components in the next 30 days”, or have done so in the last 12 months. Importers of plastic packaging should read how Plastic Packaging Tax applies to imported packaging alongside the REACH checklist below.
If you also ship chemicals out of Great Britain, see our guide to exporting chemicals from the UK under REACH and CLP.
Checklist before you import plastics to the UK
- Split every SKU into polymer, mixture or article.
- For polymers: obtain the monomer composition and confirm whether monomers at 2% w/w or more are UK REACH-registered, or covered by a GB Only Representative.
- For masterbatch and compounds: list additives and estimate annual tonnage per substance against the one-tonne threshold.
- For articles: request an SVHC declaration against the UK REACH Candidate List (0.1% w/w).
- Prepare the safe-use information you will pass to business customers, and a process for answering consumer requests within 45 days.
- Confirm the chapter 39 commodity code and whether the goods meet TCA rules of origin.
- Check the Plastic Packaging Tax 10-tonne threshold for imported packaging.
Businesses moving plastics between Poland and Great Britain often need the declaration, the origin evidence and the supplier paperwork handled in one place — the day-to-day work of a customs agency on the UK-Poland route.
Mini-FAQ
Do I need to register polypropylene pellets under UK REACH?
Not the polymer itself — polymers are exempt from registration. You may need to register monomers present at 2% w/w or more if you import one tonne or more of them a year and they are not already registered further up the supply chain.
Does my EU supplier’s EU REACH registration cover my imports into Great Britain?
No. UK REACH is a separate regime. A non-GB manufacturer can appoint a GB-based Only Representative to take on registration responsibilities.
What do I owe customers if a plastic article contains an SVHC?
Above 0.1% w/w you must give business recipients enough information for safe use, at minimum the substance name, and answer consumer requests within 45 days.
One Response