Tariff Classification of Plastic Articles

PET Plastic Waste GTIP Classification and Sampling: GGM Circular (10.04.2025)
It has been noted that, during customs procedures, problems may arise in the tariff classification (GTIP) of PET plastic waste items when they are sent for laboratory analysis. In this context, the General Directorate of Customs’ circular dated 10.04.2025 and numbered 108060203 emphasizes that the most critical point in classification is taking a sample that truly represents the goods.
Why Is Sampling So Important?
Since PET plastic waste often does not have a homogeneous structure, an incorrect or incomplete sample can directly affect the analysis result and therefore the GTIP classification. Thus, the “representative power” of the sample becomes the fundamental basis of classification.
How Should Sampling Rules Be Applied?
According to the Customs Regulation, the sample must:
•    Be taken in a way that represents the declared goods
•    Be sufficient for at least two analyses
•    Be labeled and sealed
•    Be recorded with a sample and witness sample report
In practice, uploading photographs of the goods to the system by the customs officer is also considered a supportive element during classification.
Is There a Right to Appeal the Analysis?
Yes. In cases arising from sampling, there is a right to appeal the analysis. Upon objection, a new sample can be taken in the presence of the declarant or their representative, and the analysis can be repeated. This process is particularly important when it is claimed that the sample does not represent the goods.
Position 39.15 and “Primary Forms” Distinction
In the classification of plastic waste, distinctions within Chapter 39 are critical, especially:
•    Explanations under Position 39.15
•    The definition of “primary forms”
•    The approach that waste of a single thermoplastic material converted into primary form is considered outside Position 39.15
It is also emphasized that evaluations must be made with reference to previous regulations and relevant explanations regarding PET plastic waste classification.
Brief Conclusion
In GTIP classification of PET plastic waste, the most critical step is taking a highly representative sample. Analyses conducted without proper sampling increase the risk of incorrect GTIP classification. Therefore, the sampling process and classification stage must be managed together with great care.