Recycled plastic pellets exported to the EU: which origin criterion goes on the invoice declaration? For plastics and rubber — where the “material” can be domestically collected scrap — the answer is not always “P”, and getting it wrong loses the preference.
1. Recycled plastics: when P, when W?
Under EVFTA Protocol 1: plastic scrap collected entirely in Viet Nam and reprocessed into pellets in Viet Nam may qualify as wholly obtained (criterion “P”) — because the input was obtained entirely in Viet Nam. But if the recycling line adds significant imported additives or stabilisers, or blends recycled pellets with imported virgin pellets, the product takes criterion “W” (sufficient processing) with the HS code under the product rule. In practice, many recyclers write “P” on every shipment — until EU customs asks about the imported additives and there is no answer.
2. Rubber: from latex to product
Natural rubber (field latex, ribbed smoked sheets) harvested in Viet Nam is wholly obtained “P”. Processed rubber (block rubber, blended compounds) must meet the product rule: does Vietnamese processing reach “sufficient working or processing”? Watchpoint: imported synthetic rubber blended into natural rubber changes the calculation — the non-originating value ratio must be computed. The invoice declaration must reflect reality: “P” for pure natural latex/rubber, “W” with HS code for blended, processed products.
3. Declaration wording technique
The origin declaration needs: the approved-exporter number (consignments above EUR 6,000), the correct criterion (“P” or “W” plus HS code), and the signatory’s undertaking in the standard EVFTA text. Three principles: one fixed, vetted template (never improvise); the criterion must match the filed origin worksheet — EU customs cross-checks the two; and correct classification per invoice line (one invoice may carry both “P” and “W” lines).
Conclusion
For plastics and rubber, the origin declaration is the executive summary of a whole calculation behind it. One correct letter — P or W — stands on a worksheet that must hold up under questioning.
Frequently Asked Questions
Which criterion for pellets recycled from domestic scrap?
P (wholly obtained) is possible if the scrap was collected entirely in Viet Nam. With significant imported additives or blending with imported virgin pellets, state W with the HS code.
How do natural and blended rubber declarations differ?
Field latex and pure natural rubber harvested in Viet Nam take P; block rubber and blended compounds (with imported synthetic rubber) take W with the HS code.
What is the most common declaration error for recycled plastics?
Writing P on every shipment while the line uses imported additives — when EU customs asks about the additives there is no answer, and the whole shipment loses the preference.
Can one invoice carry both P and W lines?
Yes. Each invoice line must be classified correctly; the declared criterion must match the filed origin worksheet.
