How Japan Manages Basel-Compliant Plastic Exports

—and Why the “Three-Phase Model” Is Now Essential

Japan follows the Basel Act, established by the Ministry of the Environment, which defines how plastic materials must be assessed before export (explained in detail in another Association blog).

Traditionally, the determination was divided into two categories:

1. Pre-consumer (factory-derived materials)

2. Post-consumer (used materials)

If a material was clean, free of foreign substances, and made of a single resin,

factory-derived plastics were typically considered non-Basel waste,

meaning they could be exported without being treated as “waste.”

Even for post-consumer plastics, materials processed into pellets or single-color flakes could be judged as non-Basel waste as well.

When processed with dedicated machines, even mixed-color flakes could qualify as non-waste as long as they were converted into a recognized primary product form.

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**However, a major issue has emerged:

HS Code 3915 (“Plastic Waste”) has become a global barrier.**

In recent years, many countries have tightened restrictions on HS Code 3915, regardless of a material’s Basel status.

This means that even if Japan deems a material “non-waste” under the Basel Act,

if it is classified as HS Code 3915, it may be rejected at the importing country’s border.

In other words:

Basel OK does not necessarily mean “safe to export” anymore.

To respond to this new reality, our Association believes that Basel compliance must be paired with correct HS Code classification,

which is why we published the Resource Plastic Export Three-Phase Chart.

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Why conversion into a “primary product form” is essential for safe exports

Except for unused secondary products (such as rolls or sheets),

plastics must be converted into an internationally recognized primary product form

to avoid being classified as HS Code 3915.

Global trade rules define only four primary plastic product forms:

• Pellets

• Flakes (crushed)

• Ingots (solid blocks)

• Powder

When plastics are processed into one of these four forms using dedicated machinery,

they can be exported under HS Code 3901–3914, avoiding “waste” classification.

The key point is:

→ Any form outside these four categories—such as bales/compacted plastics—automatically becomes HS Code 3915.

This is the core problem behind many recent export failures.

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Why the traditional “pre-consumer vs post-consumer” model is no longer enough

The old two-category model cannot properly classify factory-derived semi-finished products

(such as molded parts or processed secondary products).

To eliminate this ambiguity, the Association organized materials into three phases:

1. Factory-stage (pre-processing, unused materials)

2. Post-processing (semi-finished, molded, or processed secondary products)

3. Post-consumer (used materials)

This framework clarifies:

• Whether the material originated before or after processing

• Whether it must be reprocessed into a primary product form

• Whether Basel rules or HS Code rules apply

• Whether it is safe to export without becoming “plastic waste” (3915)

The long-standing gray zone around factory-derived processed products is removed, and

export decisions become consistent and easy to understand.

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Why exporting bales (compacted plastics) is now a high-risk choice

Factory-derived compacted materials and molded parts may be Basel-compliant,

but as long as their shape is not a recognized primary product form,

they will fall under HS Code 3915 (plastic waste).

This creates severe risks:

• Rejection at the importing country

• Border delays and detainment

• Return shipments (ship-backs)

• Additional transport and disposal costs

• Loss of trust with overseas buyers

Such incidents have already occurred in Asia,

and the trend is expected to intensify.

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Exporting in primary product form opens markets—not only in Asia, but also in Europe and the U.S.

Exporting plastics in one of the four primary forms

(pellets, flakes, ingots, powder)

creates a universal standard that is accepted not only in Asia but also in Europe and North America.

In many Asian countries, Japanese recycled materials are already recognized as

“Resource Plastic”, valued for their cleanliness and consistent quality.

Because domestic demand for recycled plastics remains limited in Japan,

high-quality Japanese recycled materials are increasingly regarded abroad as

a strategic export product—one that overseas manufacturers genuinely rely on.

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Conclusion: The only safe and globally accepted export method

To ensure safe, compliant, and sustainable plastic exports,

materials must meet both:

• Basel Act criteria

• HS Code “primary product” classification

This means:

→ Exporting in primary product form (pellets, flakes, ingots, powder) is the only reliable method.

The Resource Plastic Export Three-Phase Chart was published to make this determination

clear, consistent, and accessible for everyone involved in the industry.

The Resource Plastic Association will continue supporting Japan’s recycled plastics

as a trusted global resource in the circular economy.