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★Mark us as a preferred sourceNew, dedicated PET flakes customs codes will appear in the European Union’s Combined Nomenclature from 1 January 2027. Commission Implementing Regulation (EU) 2026/2163 splits the existing PET codes in two, so customs and trade statistics will finally show trade in PET flakes separately from PET pellets. The change was driven by PETCORE EUROPE, the Brussels-based association representing the European PET value chain, and the industry sees it as a long-awaited milestone.
In short: From 1 January 2027, new PET flakes customs codes apply across the EU, separating flakes from pellets and other forms of PET. The former CN codes 39076100 and 39076900 are each split in two, while the 78 ml/g viscosity threshold stays the same. The new codes still do not distinguish virgin from recycled PET.
What changes on 1 January 2027?
Until now, the EU’s tariff and trade statistics system, the Combined Nomenclature (CN), did not differentiate between the physical forms of PET. Ground and washed PET flakes and re-melted, regranulated PET pellets were declared under the same eight-digit code, with the viscosity number as the only classification criterion.
On 4 November 2026, PETCORE EUROPE announced that, under Implementing Regulation (EU) 2026/2163, each of the two existing PET codes will be divided: one subheading will cover PET flakes only, the other all remaining forms of PET. The new codes are mandatory from 1 January 2027, meaning that imports and exports of PET flakes must be declared under them from that date.
In practice, flake shipments entering or leaving the EU will appear as a distinct line in trade statistics instead of disappearing into pellet volumes.
The new PET flakes customs codes and the 78 ml/g viscosity threshold
The logic is straightforward: the existing split by viscosity number is kept, and a separate subheading for flakes is created within each branch.
| Previous CN code | New 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 forms of PET, 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 forms of PET, viscosity number below 78 ml/g |
The viscosity number reflects the length of PET’s polymer chains and, through that, how the material can be processed. The 78 ml/g threshold already divided PET in the previous code structure: higher-viscosity material is typically used for bottle production, while the lower range is more typical of fibre, film and other applications. The new rules leave this threshold unchanged and simply single out flakes as a category of their own.
Why separate flakes from pellets?
Flakes are a key intermediate product of PET recycling: collected and sorted bottles are ground and washed into flakes, which are then turned into pellets, bottles, fibres or film. As long as flakes and pellets shared a code, it was impossible to see clearly how much flake was entering Europe, from where and at what price.
This is not a theoretical concern. Cheap flake and regranulate imports from third countries are already causing serious problems in other markets: in the United States, imports from Asia and South America have become one of the main competitive pressures on domestic recyclers, as we reported in our article on the crisis facing the US plastic recycling sector. For European processors, including large new capacity in the region such as Professional Recycle’s 90,000-tonne PET plant in Târgu Mureș, it is therefore essential that the impact of flake imports can be measured.
According to PETCORE EUROPE, the separate codes bring progress in four areas:
- Market transparency: better visibility of PET flake imports and exports, especially to and from non-EU countries.
- More reliable market intelligence: closer monitoring of trade flows and of the competitive pressure on European recyclers.
- Evidence-based policymaking: more precise data to support discussions with EU institutions on circularity, competitiveness and recycled content.
- Stronger industry representation: a better ability to document market developments and identify potential distortions.
In the announcement, PETCORE EUROPE Chairman Antonello Ciotti noted that the association set up a dedicated Advocacy Working Group in recent years to represent the needs of the PET value chain to the EU institutions faster and more effectively. He described the new codes as a result of that sustained engagement.
What the new codes still do not show
An important limitation is that the code structure only separates PET by physical form. The new subheadings do not distinguish virgin from recycled PET (rPET), nor food-contact from non-food-contact grades. A declaration will therefore still not reveal whether flakes come from returned bottles or industrial production scrap, or whether they are suitable for bottle-to-bottle recycling.
This matters because demand for recycled PET is increasingly driven by legal obligations. The EU Packaging and Packaging Waste Regulation (PPWR) sets a minimum of 30 percent recycled content for plastic beverage bottles by 2030, and some producers are going much further: Asahi Beverages, for example, has switched its soft-drink bottles entirely to rPET in Australia.
PETCORE EUROPE is therefore continuing its work towards a dedicated rPET customs code, which the association expects once the necessary procedures are in place.
What it means for companies in Hungary and Central Europe
The change affects every PET recycler, trader and converter that imports PET flakes from, or exports them to, countries outside the EU. These companies should review their product codes and customs declaration templates before the end of 2026 and check with their customs agent that declarations are filed under the correct new subheading from 1 January.
In the longer term, the change can also support better decision-making in the sector. As data under the new codes build up in EU external trade statistics, it will become visible how much flake moves between Europe and third countries, and how this compares with the volumes of bottles collected through national deposit return systems, including Hungary’s, launched in 2024. That measurability can help both in planning domestic recycling capacity and in documenting market distortions.
Frequently asked questions about PET flakes customs codes
When do the new PET flakes customs codes apply?
The new PET flakes customs codes apply across the European Union from 1 January 2027. They are introduced into the Combined Nomenclature by Commission Implementing Regulation (EU) 2026/2163. From that date, imports and exports of PET flakes must be declared under eight-digit CN codes that are separate from those used for pellets and other forms of PET.
Which codes replace CN codes 39076100 and 39076900?
Both former codes are split in two. For PET with a viscosity number of 78 ml/g or higher, flakes move to 39076110 and other forms to 39076190. Below 78 ml/g, flakes are classified under 39076910 and other forms of PET under 39076990. The threshold itself is unchanged; only flakes have become a separate category.
Do the new codes distinguish virgin from recycled PET?
No. The new codes only separate PET by physical form, distinguishing flakes from pellets and other forms. They do not differentiate virgin from recycled PET (rPET), nor food-contact from non-food-contact grades. PETCORE EUROPE is therefore continuing its efforts to obtain a dedicated rPET customs code once the necessary procedures are in place.
Why does the change matter for European PET recyclers?
Because trade statistics have so far not shown how much PET flake enters the EU from outside. Separate codes make flake import flows visible, allow the competitive pressure of cheap imports to be measured more precisely, and give the industry stronger data when discussing circularity, competitiveness and possible market distortions with the EU institutions.
What does the 78 ml/g viscosity threshold mean?
The viscosity number reflects the length of PET’s polymer chains and therefore how the material can be processed. The 78 ml/g threshold already divided PET in the previous code structure. Higher-viscosity material is typically used for bottle production, while the lower range is more typical of fibre, film and other applications. The new rules leave this threshold unchanged.
🔗 Official sources and references: 👉
- PETCORE EUROPE – New EU Customs Codes for PET Flakes from January 2027
- PETCORE EUROPE – press release (PDF)
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