2026 Southeast Asia Recycled Materials Import Customs Brokerage Full Process Operation Guide

1.Southeast Asia Recycled Materials Import: New Challenges and Old Problems in 2026

In 2026,Southeast Asia has become the main source of recycled materials imports to China.The supply of recycled plastic pellets from Thailand,Malaysia and Vietnam accounts for more than 60% of the total domestic imports.The advantages of this region include sufficient supply,relatively stable prices and short transportation cycles.However,the complexity of supervision has risen sharply accordingly.Customs’ standards for determining solid waste attributes have become increasingly strict,the review period for environmental approval documents has been extended,and the port inspection rate has increased by nearly 15 percentage points compared with the same period in 2025.

An injection molding enterprise in Kunshan where Supervisor Xiao works imported three containers of recycled PP pellets from Malaysia at the beginning of the year.After the goods arrived at the port,they were subject to customs control and inspection because there was a dispute between the declared HS code and the actual form of the goods,and the port required a solid waste attribute identification report.The delay lasted for 22 full days,resulting in nearly 80,000 yuan in demurrage and storage fees.Such situations are not uncommon in 2026.Many enterprises underestimate the technical threshold of recycled materials import,thinking that as long as the supplier provides invoices and bills of lading,they can clear customs smoothly,but end up stumbling in links such as document pre-examination,classification review and commodity inspection.

2.Practical Role of Zhongshen in the Recycled Materials Import Chain

Zhongshen has been deeply engaged in recycled materials customs declaration business in Shanghai Port for more than 20 years,and has handled cases covering various plastic pellets such as recycled PE,PP,PET,ABS,as well as recycled pulp,recycled metal and other categories.Our role is not just a document transmitter,but a risk control hub for the import process.From arranging CCIC inspection before overseas shipment,to applying for domestic environmental approval documents; from providing pre-classification suggestions before the goods arrive at the port,to on-site coordination during the inspection link; from designing compliant paths for foreign exchange payment,to the complete chain of VAT deduction,each node requires professional judgment.

The Zhongshen recycled materials business team led by Manager Mao currently has seven full-time staff,who are respectively responsible for four lines: customs classification,commodity inspection,environmental approval and foreign exchange management.In March 2026,we assisted a customer in Changzhou to handle a batch of recycled HDPE pellets imported from Thailand,and the goods were subject to risk control at Yangshan Port.The three documents we prepared in advance: pre-shipment inspection report,production process description and raw material source certificate,resolved the customs’ solid waste concerns on the day of inspection,and the goods were released the next day.This response speed is based on daily continuous tracking of regulatory policies and accumulation of internal case databases.

3.Full Process Breakdown and Compliance Key Points of Recycled Materials Import

1.Document Pre-examination: Keep Risks Out Before Shipment

Document pre-examination is the most important but easily overlooked link in recycled materials import.In 2026,the core of customs supervision on recycled materials is the "three consistencies": consistent document information,consistent goods attributes and consistent declaration elements.Before customers make payment,Zhongshen will require overseas suppliers to provide four core documents: complete pre-shipment inspection certificate (CCIC),raw material source description,production process flow chart and composition test report.We have an internal scoring sheet to score the documents provided by suppliers in three aspects: completeness,rationality and compliance.Goods with a score lower than 70 are recommended to delay shipment.

Take recycled PET scraps imported from Vietnam as an example.The product description on the CCIC certificate must be precise to "post-consumer recycled PET bottle flakes treated with cleaning,crushing and sorting processes",rather than vaguely writing "recycled plastic".In the composition test report,the PVC content must not exceed 0.5%,and heavy metal residues must comply with GB 38400-2025 standard.If these details are found before overseas shipment,the modification cost is almost zero; if problems are found at the port,the loss of return or destruction may be as high as 80% of the cargo value.

2.Port Customs Declaration: Dual Tests of Price and Classification

HS code classification of recycled materials has always been the focus of customs document review.In 2026,recycled PE pellets are classified under 3901.9090,and recycled PP pellets are classified under 3902.9000,but the premise is that the goods must meet two conditions: "primary shape" and "single type".If the pellets have mixed colors,large viscosity differences or contain other plastic components,they may be classified under 3825.9000 (other by-products of the chemical industry and related industries),or even be regarded as solid waste.

In terms of price declaration,customs is very sensitive to the price monitoring of recycled materials.Before customs declaration,Zhongshen will retrieve the port transaction price data of similar goods in the last three months,and combine the current international plastic raw material price trends to formulate a reasonable declared price range for customers.In April 2026,a Zhejiang enterprise was issued a price query notice because the declared price was 30% lower than the customs risk parameter.We immediately submitted three supporting materials: the original purchase contract of the supplier,the current domestic recycled materials market report in Vietnam and the foreign exchange payment slip.Finally,the customs accepted our declared price.

3.Commodity Inspection: Life-and-Death Gate of Solid Waste Identification

Commodity inspection is the most dangerous link in recycled materials import.In 2026,the port adopts a dual-track system of "sensory inspection + laboratory testing" for solid waste attribute identification of recycled materials.Inspection officers first observe the color,odor and impurity content of the goods.If the pellets are black in color,have pungent odor,and visible impurities exceed 5%,they will directly take samples for testing.The laboratory testing cycle usually takes 15 working days,during which the goods must stay in the supervision area,and the demurrage fee is as high as 1,000 yuan per day.

Zhongshen’s on-site coordinators will arrive at the terminal early on the day of inspection to assist inspection officers in opening containers,unpacking and sampling.We will carry the production process video,raw material source photos and supplier’s environmental certification documents of the batch of goods,and explain the processing flow and quality control standards of the goods to the officers on site.In May 2026,when a batch of recycled ABS pellets imported from Malaysia was inspected at Wusong Port,the officers questioned the color of the goods.We played the cleaning and granulation videos of the supplier’s workshop on site and presented proof that the raw materials were crushed electronic and electrical appliance shells.Finally,the officers judged the goods as qualified,did not take samples for testing,and the goods were released on the same day.

4.Practical Case: Customs Clearance Process of a Batch of Recycled PP Pellets

In June 2026,the trading company where Supervisor Xiao works imported 40 tons of recycled PP pellets from Thailand,with a value of 68,000 US dollars,which are planned to be used for the production of automotive interior parts.Before the goods were shipped,Zhongshen intervened in document pre-examination and found that the goods description on the CCIC certificate provided by the supplier was "recycled polypropylene pellets",but the raw material source was not indicated.We required the supplier to supplement the description and provide proof that the raw materials were crushed woven bags.

Before the goods arrived at the port,we submitted a pre-classification application to the customs and confirmed the HS code as 3902.9000.After the customs declaration form was submitted,the system prompted risk control and required inspection.On the day of inspection,Manager Mao brought the complete documents to the site,including the supplier’s ISO14001 certification,raw material purchase invoice and production process description.After the officers opened the container,they found that the goods were translucent pellets,odorless and with very few impurities,which were exactly consistent with the photos we provided.After passing the sensory inspection,the officers did not take samples for testing,and the goods were released the next day.It only took 3 days from arrival at the port to release.

Supervisor Xiao later calculated that if this batch of goods was sampled for testing,it would be delayed for at least 15 days,and the total demurrage,storage and testing fees would amount to more than 30,000 yuan,which might also affect the production plan of downstream customers.With Zhongshen’s early intervention,the entire process was smooth and the costs were controllable.

5.Value of Professional Agency: Not Just Speed Up

Many enterprises believe that the value of customs brokerage is only to speed up customs clearance,which is too one-sided.In the recycled materials import business,the core value of Zhongshen is reflected in three aspects: risk identification,cost control and compliance guarantee.In 2026,customs’ regulatory policies for recycled materials are adjusted every quarter,and the requirements for environmental approval documents are also constantly updated.It is difficult for enterprises to grasp them in real time on their own.We hold internal policy interpretation meetings every week,translate the latest regulatory dynamics into specific operation guidelines,and inform customers in advance which goods have high risks and which documents must be supplemented.

In terms of cost control,Zhongshen reduces the cost expenditure of individual customers through batch operations.Take foreign exchange payment as an example,the bank we cooperate with can provide more favorable exchange rates,and the single payment fee is 30% lower than that handled by enterprises themselves.In terms of warehousing,we have contracted warehouses in Shanghai Waigaoqiao and Yangshan Port,with a free storage period 7 days longer than ordinary customers,which can save a lot of costs in the transit link.

Compliance guarantee is the most easily overlooked value.In 2026,recycled materials import enterprises face not only the risk of administrative penalties from customs,but also follow-up supervision from environmental protection departments.Zhongshen will establish a complete import file for customers,including environmental approval documents,CCIC certificates,customs declaration forms and payment records for each batch of goods,forming a closed-loop evidence chain.Once encountering follow-up audits,these files can respond quickly and avoid enterprises from falling into passive situations.Manager Mao often says that the real value of customs brokerage is to allow enterprises to focus on production and sales under the premise of compliance,rather than spending time on complex documents and processes.

• Risk 1: Unqualified solid waste attribute identification.The goods are judged as solid waste,facing return or destruction,with losses exceeding 80% of the cargo value.
• Risk 2: Incorrect HS code classification.The declared code is inconsistent with the actual goods,and the customs will impose a penalty for incorrect classification,with the fine amount ranging from 50% to 2 times the tax amount.
• Risk 3: Inconsistent environmental approval document and goods.The quantity,type and source on the approval document are inconsistent with the actual imported goods,and the environmental protection department may revoke the approval document and include the enterprise in the blacklist.